This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- In the early hours of July 5, 2012, the Defendant, Requildo Cardenas, shot and killed an unknown intruder through his front door, who was later identified as his friend, Matthew Lujan. Lujan had arrived at Cardenas's home, enraged from a fight at a party, and began knocking and pounding on the door loudly enough to wake Cardenas from sleep. Cardenas, not recognizing the intruder and receiving no response to his demand for identification, fired a single fatal shot (paras 2-3).
Procedural History
- During a previous trial, a jury acquitted Defendant of second-degree murder but could not reach a verdict on the voluntary manslaughter charge. The district court declared a mistrial, and the case went to trial again based solely on the voluntary manslaughter charge (para 23).
Parties' Submissions
- Defendant-Appellant: Argued that the district court erred in denying his requested jury instructions on defense of habitation and involuntary manslaughter, asserting that there was adequate evidence presented to warrant the giving of both instructions (para 2).
- Plaintiff-Appellee (State): Contended that the defense of habitation instruction was not warranted because there was no evidence that a violent felony was immediately at hand and no evidence that Defendant intended to kill Lujan to prevent the commission of a violent felony (paras 8, 15).
Legal Issues
- Whether the district court erred in refusing Defendant’s request for a defense of habitation instruction and an involuntary manslaughter instruction (para 2).
Disposition
- The Court of Appeals of New Mexico reversed the district court's decision, concluding that there was sufficient evidence to support the instructions for defense of habitation and involuntary manslaughter (para 22).
Reasons
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The Court, per Judge Roderick T. Kennedy with Judges Michael D. Bustamante and Linda M. Vanzi concurring, found that the defense of habitation instruction was warranted based on the evidence presented at trial. This evidence included the circumstances under which Lujan was shot, such as the time of the incident, the actions of Lujan that led Cardenas to believe a violent felony was imminent, and the lack of response from Lujan when Cardenas demanded identification. The Court also determined that an involuntary manslaughter instruction should have been given, as the jury could have found that Cardenas committed a lawful act without due caution or circumspection, potentially leading to a criminally negligent killing (paras 6-21).
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