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

• On April 30, 2017, several inmates at the Otero County Detention Center, including the Defendants, defied a lockdown order during a shift change. This defiance involved attempting to block the entrance to their pod with a mattress and plastic cots and using liquid soap to make the stairs slippery. The situation escalated into a physical confrontation with the correction officers, lasting about ninety seconds until control was regained through the use of pepper spray, tasers, and shock shields (para 2).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendants: Argued that the assault on a jail statute is unconstitutionally vague, the jury instruction on assault on a jail failed to accurately reflect the law, and the evidence was insufficient to support their convictions. Anderson also contended that the district court erred by not instructing the jury on lesser included offenses and by denying his motion to continue (paras 1, 7, 13, 22, 27, 31).
• State: Contended that the assault on a jail statute is not unconstitutionally vague, the jury instructions were appropriate, and the evidence was sufficient to support the Defendants' convictions. The State also argued against the necessity of instructing the jury on lesser included offenses and supported the denial of Anderson's motion to continue (paras 7, 13, 22, 27, 31).

Legal Issues

• Whether the assault on a jail statute is unconstitutionally vague.
• Whether the jury instruction on assault on a jail failed to provide an accurate rendition of the relevant law.
• Whether the evidence was sufficient to support the Defendants' convictions.
• Whether the district court committed reversible error by refusing to instruct the jury on lesser included offenses and by denying Anderson's motion to continue (paras 7, 13, 22, 27, 31).

Disposition

• The Court affirmed the Defendants' convictions for assault on a jail (para 37).

Reasons

• The Court found that the assault on a jail statute is not unconstitutionally vague, as it provides persons of ordinary intelligence a fair opportunity to understand what conduct is prohibited and does not encourage arbitrary enforcement. The statute's language, "assaulting or attacking any jail," is straightforward and does not require a specific intent element that was present in historical versions of the law (paras 8-12).
  The Court determined that the district court did not commit fundamental error in instructing the jury regarding assault on a jail. The jury instructions did not constitute fundamental error because they did not result in a fundamentally unfair trial. The instructions provided the jury with an accurate rendition of the relevant law, and the evidence presented at trial supported the convictions (paras 13-21).
  The Court concluded that the district court did not commit reversible error in refusing Anderson's request to instruct the jury on lesser included offenses. Neither disorderly conduct nor evading or obstructing an officer is a lesser included offense of assault on a jail under the circumstances of this case (paras 22-26).
  The Court held that the State presented sufficient evidence to support the Defendants' convictions. The evidence showed that the Defendants participated in actions that attacked the jail and imperiled its function and safety, satisfying the State's burden under the assault on a jail statute (paras 27-30).
  The Court found that the district court did not abuse its discretion in denying Anderson's motion for a continuance. The decision was within the court's discretion, considering factors such as the length of the requested delay, the likelihood that a delay would accomplish the movant's objectives, and the degree of inconvenience to the parties and the court (paras 31-36).