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 Defendant was involved in two transactions where he sold narcotic pills to an undercover narcotics enforcement agent and a confidential informant. In the first transaction, the Defendant exchanged five oxycodone pills for a backpack containing a computer projector. In the second transaction, he sold five oxycodone pills. The undercover agent testified about these transactions at trial, but the confidential informant did not testify (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court committed reversible error by denying the opportunity to cross-examine the undercover agent about a prior instance of untruthfulness and a conversation between the agent and a confidential informant. Also argued that presenting an entrapment defense was improperly denied, and that the order to return the computer projector was incorrect (para 1).
• Plaintiff-Appellee: Objected to the Defendant's attempt to cross-examine the undercover agent about a prior instance of untruthfulness on the grounds of relevance and improper impeachment. Did not provide specific counterarguments to the Defendant's other claims in the provided text (paras 4, 8).

Legal Issues

• Whether the district court erred in limiting the Defendant's cross-examination of the undercover agent regarding a prior act of misrepresentation (para 6).
• Whether the exclusion of testimony about the undercover agent's prior misrepresentation violated the Defendant's confrontation rights under the Sixth Amendment of the United States Constitution and Article II, Section 14 of the New Mexico Constitution (para 6).

Disposition

• The Court of Appeals reversed the Defendant's convictions due to the district court improperly limiting the Defendant's cross-examination, contrary to Rule 11-608 NMRA. The Court left the Defendant's other arguments unexamined (para 1).

Reasons

• The Court, led by Judge French and concurred by Judges Wechsler and Garcia, found that the district court's decision to exclude the Defendant's line of inquiry into the undercover agent's prior act of misrepresentation was an abuse of discretion under Rule 11-608(B)(1). This rule generally permits cross-examination about specific instances of conduct probative of the witness’s character for truthfulness. The Court reasoned that testimony about a purported recent admission under oath by the undercover agent of an untruthful or inaccurate police report he authored is probative of his character for truthfulness. The Court also determined that the error was not harmless, as the State relied solely upon the testimony of the undercover agent to establish all the critical elements of its case against the Defendant, making the agent's credibility central to the case. Therefore, there was a reasonable probability that the erroneous exclusion of the Defendant's challenge to the undercover agent's character for truthfulness contributed to the Defendant's conviction (paras 6-20).