AI Generated Opinion Summaries

Decision Information

Decision Content

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 case involves the State's failure to timely disclose a witness, leading to the Defendant's motion to prohibit the State from calling the undisclosed witness. The district court granted the motion, excluding the testimony of the State's witness as a sanction for the failure to disclose.

Procedural History

  • District Court of Bernalillo County: The testimony of one of the State’s witnesses was excluded as a sanction for failure to properly disclose the witness.

Parties' Submissions

  • Appellant (State): Argued that the Defendant's motion for sanctions was untimely and that the district court did not adequately explain its reasoning for excluding the witness's testimony.
  • Appellee (Defendant): Moved to prohibit the State from calling undisclosed witnesses, arguing that the State had not complied with the required disclosure of the witness's name, contact information, and a summary of his testimony within the specified timeframe.

Legal Issues

  • Whether the Defendant's motion to exclude the State's witness for failure to disclose was untimely.
  • Whether the district court adequately explained its reasoning for excluding the witness's testimony as a sanction.

Disposition

  • The district court's decision to exclude the testimony of the State’s witness was affirmed.

Reasons

  • IVES, Judge; LINDA M. VANZI, Judge; J. MILES HANISEE, Judge: The panel affirmed the district court's sanction, rejecting the State's argument that the Defendant's motion was untimely and finding that the district court had the authority to impose sanctions sua sponte for discovery violations. The appellate court concluded that the district court's order on remand adequately addressed the considerations required by precedent, including culpability, prejudice, and lesser sanctions, thus satisfying the explanation requirement for excluding the witness's testimony (paras 4-9).
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