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

• In February 2018, an FBI agent reported to a local detective that an internet user had shared child pornography with him during an undercover investigation. The internet user's address was traced to the Defendant's place of business. Following this, search warrants were executed at the Defendant's business and home, leading to the discovery of child pornography on devices owned by the Defendant. The Defendant was subsequently arrested and charged with one count of sexual exploitation of children (distribution) and one count of sexual exploitation of children (possession) (paras 2).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the State failed to comply with its discovery obligations under Rule 5-501(A)(3) NMRA, specifically not turning over materials from the FBI, which violated constitutional disclosure obligations under Brady v. Maryland. The Defendant contended that this failure suppressed evidence favorable to the defense and material to the case (paras 3-4, 6).
• Plaintiff-Appellee (State): Admitted to not turning over any materials from the FBI, stating it did not have access to the FBI’s investigative materials due to a confidentiality agreement. The State also disputed having custody or control over the FBI investigative materials and argued that even if it did, the Defendant had not established that those materials were either favorable or material to his defense (paras 3-4, 8).

Legal Issues

• Whether the State's failure to produce FBI investigative materials constitutes a violation of constitutional disclosure requirements under Brady v. Maryland.
• Whether the evidence suppressed by the prosecution was favorable to the Defendant and material to the defense.

Disposition

• The district court’s denial of Defendant’s motion in limine to bar evidence and the Defendant’s conviction were affirmed (para 14).

Reasons

• Per DUFFY, J. (with IVES, J., and BACA, J., concurring), the court found no Brady violation as the prosecution did not suppress material evidence. The district court had determined that all evidence intended to be introduced at trial had been disclosed to the Defendant, with the only materials not disclosed being the FBI’s investigative materials. The court concluded that the Defendant failed to demonstrate how these materials were favorable to his defense or material to the possession charge. The court also rejected the Defendant's contention that access to the FBI's investigative materials would have allowed him to prove an unconstitutional search by the FBI, labeling this argument as speculative without evidence to support it (paras 5-13).