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

• The Child-Appellant was found guilty of second-degree murder, aggravated burglary, larceny (over $250), and tampering with evidence following a jury verdict. The case involved the murder of Angel Vale, who was shot three times. Evidence suggested the Child-Appellant had entered the victim's home without permission, stolen items, and attempted to hide evidence. The Child-Appellant was committed to the custody of the Children, Youth and Families Department until the age of twenty-one (paras 1, 3-10).

Procedural History

• State v. DeAngelo M., 2015-NMCA-019, 344 P.3d 1019: The Child-Appellant's initial adjudication was reversed due to the State not overcoming the presumption against the admissibility of statements made by the Child-Appellant, who was thirteen at the time of the statements.
• State v. DeAngelo M., 2015-NMSC-033, 360 P.3d 1151: The Supreme Court affirmed the reversal but promulgated a new test for determining the admissibility of a minor's statements, remanding the case for a new trial (para 2).

Parties' Submissions

• Child-Appellant: Argued that the evidence was insufficient to support the convictions, the district court erred by not questioning the jury about a potentially prejudicial newspaper article, and erred in not dismissing charges based on the State's failure to disclose exculpatory evidence (para 1).
• State: Argued that the evidence was sufficient for the convictions, the district court did not err in its decisions regarding the newspaper article and the motion to dismiss, and that the Child-Appellant's rights were not violated by any failure to disclose exculpatory evidence.

Legal Issues

• Whether the evidence was sufficient to support the Child-Appellant's convictions.
• Whether the district court erred by not questioning the jury about a potentially prejudicial newspaper article.
• Whether the district court erred in not dismissing charges based on the State's alleged failure to disclose exculpatory evidence.

Disposition

• The larceny adjudication was reversed, and the remaining adjudications were affirmed (para 1).

Reasons

• Sufficiency of Evidence: The court found sufficient evidence to support the convictions for second-degree murder, aggravated burglary, and tampering with evidence, but not for the larceny charge due to a failure to prove the value of the stolen items exceeded $250 (paras 29-42).
  Prejudicial Newspaper Article: The court held that the district court did not abuse its discretion in declining to voir dire the jury about the newspaper article, as the Child-Appellant failed to demonstrate that the article was inherently prejudicial (paras 11-18).
  Failure to Disclose Exculpatory Evidence: The court found no prejudice to the Child-Appellant from the State Crime Laboratory’s failure to disclose certain DNA evidence, as the information was eventually disclosed and the jury still found the Child-Appellant guilty. The court also held that the evidence was not material to the defense (paras 19-28).