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 State filed an Inspection of Public Records Act (IPRA) request with the sheriff's office, which resulted in the provision of redacted documents to the defense. This action was taken after a district court had previously declared a mistrial and ordered the State to provide certain personnel information to the defense without exceptions or conditions. The State's decision to submit an IPRA request and provide incomplete discovery was found to be a violation of discovery rules and the court's order.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• State: Argued that the Defendant should have filed a motion to obtain a ruling on the materiality of the records involved in a discovery dispute, similar to a previous case (State v. Pohl). The State suggested that if the defense wanted another determination of material relevance, they should file a motion for the court and the State to be put on notice and make a showing of materiality.
• Defendant: [Not applicable or not found]

Legal Issues

• Whether the State's decision to obtain redacted copies of reports through an IPRA request, expecting the Defendant to relitigate the materiality of the reports, complied with the prior discovery order.
• Whether the district court correctly applied legal principles in exercising its discretion regarding discovery sanctions.

Disposition

• The order of the district court excluding witnesses as a sanction for the State’s violation of discovery rules and the district court’s discovery order was affirmed.

Reasons

• Per J. Miles Hanisee, with Jennifer L. Attrep and Zachary A. Ives concurring, the court found that the district court did not abuse its discretion in excluding witnesses as a sanction for the State's violation of discovery rules and the court's order. The State's argument that the Defendant should have filed a motion for a ruling on the materiality of the records was not persuasive, especially since the district court had already found the personnel information relevant and material. The State's actions were deemed a violation of Rule 5-501 NMRA, LR2-308, and the district court's January 10, 2020, order. The appellate court also noted that the district court did not misapply any proper legal principles in its decision regarding discovery sanctions (paras 1-6).