AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• On July 3, 2014, in Gallup, New Mexico, a physical altercation occurred in a vacant dirt lot involving the Defendant, her sister, the Victim, and the Victim's girlfriend. The fight, partially recorded by a bystander, escalated to the point where the Defendant threw the Victim to the ground and kicked her in the head. Following the altercation, the Victim was found dead in her tent the next afternoon. The Defendant was subsequently arrested and convicted of voluntary manslaughter for her actions during the altercation (paras 2-4).

Procedural History

• Court of Appeals of New Mexico, May 17, 2018: The Defendant's conviction for voluntary manslaughter was affirmed.

Parties' Submissions

• Appellant: Argued that the evidence was insufficient to prove her actions caused the Victim's death, the trial was unfair due to the refusal to excuse a biased juror, and the jury's consideration of new evidence during deliberations warranted a new trial (para 1).
• Appellee: Contended that the evidence was sufficient to support the conviction, the juror in question could remain impartial, and the viewing of the entire interrogation video by the jury did not prejudice the Defendant's case.

Legal Issues

• Whether there was sufficient evidence to support the Defendant's conviction for voluntary manslaughter.
• Whether the Defendant was denied a fair trial due to the refusal to excuse a particular juror for cause.
• Whether the district court erred in denying the Defendant's motion for a new trial based on the jury's consideration of new evidence during its deliberations.

Disposition

• The Court of Appeals affirmed the Defendant's conviction for voluntary manslaughter (para 1).

Reasons

• The Court, led by Judge Daniel J. Gallegos, with Judges J. Miles Hanisee and Henry M. Bohnhoff concurring, found that:
  Sufficiency of the Evidence: The evidence, including eyewitness testimony and video evidence, was sufficient to support the jury's verdict. The medical testimony indicated that the Victim's death was caused by a subdural hemorrhage resulting from blunt force trauma to the head, which the Defendant's kick could have caused (paras 5-10).
  Juror Bias: The district court did not abuse its discretion in refusing to excuse the juror in question for cause. The court was satisfied that the juror could remain impartial despite her personal history, distinguishing this case from precedent where bias was more clearly expressed (paras 11-16).
  Viewing of Admitted, but Previously Unviewed, Video Evidence During Jury Deliberations: The Defendant waived her right to object to the jury's viewing of the entire interrogation video by failing to object at several points during the trial. Furthermore, the viewing did not constitute fundamental error as it did not result in a miscarriage of justice or undermine the integrity of the judicial process (paras 17-30).