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 Defendant was on probation when he was pulled over by New Mexico State Police Lieutenant Henderson for crossing the lane line several times on March 16, 2016. During the stop, the Defendant was unable to produce a valid driver's license. These actions led to the revocation of his probation by the district court, which committed him to the Department of Corrections.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court abused its discretion in revoking his probation due to insufficient evidence of a violation. Contended that his inability to show a driver's license at the time of the stop should not be equated with not having a valid driver's license and that the State failed to prove he did not possess a valid license. Also argued that the State did not demonstrate his violation was willful, which is a requisite for probation revocation (paras 2-4).
• Plaintiff-Appellee: Asserted that there was sufficient evidence to establish to a reasonable certainty that the Defendant violated his probation by failing to maintain a traffic lane, driving without a valid driver's license, and failing to seek, obtain, and maintain employment. Highlighted Lieutenant Henderson's testimony as proof of the Defendant's violation (para 3).

Legal Issues

• Whether the district court abused its discretion in revoking the Defendant's probation based on the alleged insufficient evidence of a violation.
• Whether the Defendant's violation of probation conditions was willful, a necessary condition for revocation.

Disposition

• The Court of Appeals affirmed the district court's second order revoking the Defendant's probation and committing him to the Department of Corrections (para 5).

Reasons

• Per LINDA M. VANZI, J. (JAMES J. WECHSLER, J., and STEPHEN G. FRENCH, J., concurring): The Court found that there was sufficient evidence to support the revocation of the Defendant's probation. It highlighted Lieutenant Henderson's testimony about the traffic stop and the Defendant's inability to produce a valid driver's license as proof of violation. The Court also noted that the Defendant did not produce a valid driver's license during his probation revocation hearing, which was necessary to avoid conviction under NMSA 1978, Section 66-5-2(C) (2013). Regarding the willfulness of the Defendant's violation, the Court pointed out that once the State offers proof of a breach of a material condition of probation, the burden shifts to the Defendant to show that the non-compliance was not willful. The Court concluded that the Defendant did not meet this burden, thus the district court was within its discretion to revoke his probation (paras 3-5).