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 August 2007, a seventeen-year-old child attended a party, consumed a significant amount of alcohol in violation of his probation terms, and participated in a violent attack on a young man who subsequently died from the injuries. The child was charged with second-degree murder among other charges. He entered a plea agreement, pleading no contest to aggravated battery and conspiracy to commit aggravated battery, with other charges dismissed. The agreement outlined potential sentencing as either juvenile or adult, with the district court to decide based on an amenability hearing.

Procedural History

• Appeal from the District Court of Luna County, Henry R. Quintero, District Judge: The district court determined the child was not amenable to treatment and sentenced him as an adult.

Parties' Submissions

• Child-Appellant: Argued that the constitutionality of NMSA 1978, Section 32A-2-20 (2005) was in question, asserting that a jury should determine his amenability to treatment as a juvenile. Additionally, claimed the district court abused its discretion or lacked sufficient evidence in determining non-amenability to treatment.
• Plaintiff-Appellee (State): Countered that the child waived the right to challenge the amenability determination by entering the plea agreement and argued that substantial evidence supported the district court's decision.

Legal Issues

• Whether the constitutionality of NMSA 1978, Section 32A-2-20 (2005) allows for a judge rather than a jury to determine a child's amenability to treatment as a juvenile.
• Whether the district court abused its discretion or lacked sufficient evidence in determining the child was not amenable to treatment.

Disposition

• The Court of Appeals affirmed the sentence imposed by the district court, rejecting the child's constitutional challenge and finding substantial evidence supported the non-amenability determination.

Reasons

• Per CELIA FOY CASTILLO, Chief Judge (JONATHAN B. SUTIN, Judge, CYNTHIA A. FRY, Judge concurring):
  The court dismissed the constitutional challenge based on precedent from State v. Rudy B., which upheld judge-made amenability decisions against a Sixth Amendment challenge. It found that the historical practice and the interference with juvenile justice administration did not require jury involvement in amenability determinations. Regarding the claim of insufficient evidence or abuse of discretion, the court noted that the plea agreement potentially waived the child's right to challenge the amenability determination. However, it found the argument moot as substantial evidence, including expert testimony and the child's history, supported the district court's decision. The court emphasized the district court's discretion in such matters and the adequacy of evidence presented, including the violent nature of the offense, the child's disregard for rules and others' rights, and expert opinions on the child's non-amenability to treatment within the juvenile system's constraints.