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 October 18, 2013, around 7:30 p.m., a two-vehicle accident occurred involving a Ford Bronco and a Toyota 4Runner, resulting in one fatality. The defendant, Emily A. Ruffin, identified as the driver of the Toyota 4Runner, was arrested for homicide by vehicle and driving under the influence after Deputy Armijo detected an odor of alcohol. Ruffin claimed the accident happened as she was distracted by her phone, and the Ford Bronco swerved in front of her (paras 2, 12).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellant (State of New Mexico): Argued that Deputy Armijo should be qualified as an expert witness in crash investigations to testify about the cause of the crash, based on his training and experience, and that his testimony would help educate the jury about the accident's dynamics (paras 11, 12).
• Defendant-Appellee (Emily A. Ruffin): Contended that Deputy Armijo's proposed expert testimony should be excluded under Rule 11-403 NMRA due to a legitimate risk of misleading the jury and argued that his testimony should be limited to his personal observations at the accident scene (para 4).

Legal Issues

• Whether the district court erred in prohibiting Deputy Armijo from testifying as to any conclusions he reached as a result of his investigation, including those that could be deemed "lay opinions."
• Whether the district court erred in prohibiting Deputy Armijo from testifying as an expert under Rule 11-702.
• Whether the district court erred in excluding Deputy Armijo’s expert testimony under Rule 11-403 (paras 12).

Disposition

• The Court of Appeals affirmed in part, reversed in part, and remanded for further proceedings. It concluded that the State properly appealed, the district court did not err in excluding Deputy Armijo’s scientific expert testimony, and the district court erred in excluding his non-scientific expert testimony (para 35).

Reasons

• The Court of Appeals found that Deputy Armijo's proposed testimony fell into two categories: non-scientific and scientific expert testimony. The court determined that the district court applied the wrong legal standard (Alberico-Daubert) to Deputy Armijo's non-scientific expert testimony, which was based on his personal observations and specialized training, not on scientific knowledge. Therefore, it was an abuse of discretion to exclude this testimony. However, the court agreed with the district court's decision to exclude Deputy Armijo's scientific expert testimony regarding the cause of the rollover, as it required application of scientific principles and mathematical calculations, which Deputy Armijo admitted he did not perform. The court also concluded that the district court abused its discretion under Rule 11-403 by excluding Deputy Armijo's non-scientific expert testimony, as there was no danger of unfair prejudice or misleading the jury that substantially outweighed the probative value of his testimony (paras 21-34).