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 convicted of driving while under the influence (DWI) following a bench trial in metropolitan court. The conviction was subsequently affirmed by the district court upon the Defendant's appeal for on-record review.

Procedural History

• Metropolitan Court: Defendant convicted of DWI.
• District Court of Bernalillo County, Judith Nakamura, District Judge: Affirmed metropolitan court's conviction (N/A).
• Court of Appeals of New Mexico, 2015-NMCA-033, 346 P.3d 372: Reviewed the appeal from the district court's decision.

Parties' Submissions

• State: Argued that there is no express right to appeal or grant of jurisdiction to the Court of Appeals from a district court’s on-record appellate review of a metropolitan court conviction for DWI.
• Defendant: Appealed the district court's affirmation of his DWI conviction, challenging the appellate jurisdiction and the right to appeal to the Court of Appeals.

Legal Issues

• Whether the Court of Appeals has jurisdiction to hear appeals from a district court’s on-record review of a metropolitan court decision.
• Whether the Defendant has a right to appeal to the Court of Appeals from the district court's decision affirming a metropolitan court conviction for DWI.

Disposition

• The Court of Appeals denied the State's motion to dismiss, allowing the Defendant's appeal to proceed to be calendared on its merits.

Reasons

• The Court of Appeals, per Judge Michael E. Vigil, with Judges M. Monica Zamora and J. Miles Hanisee concurring, held that both the Court's jurisdiction and a litigant's right to appeal must derive from a statute or constitutional provision. The Court distinguished between "jurisdiction" and a litigant's "right to appeal," noting that jurisdiction refers to the Court's power to decide the issue before it, while the right to appeal is given vitality by legislative authority. The Court found that its jurisdiction and the Defendant's right to appeal are supported by the New Mexico Constitution and statutory provisions. Specifically, the Court concluded that Section 34-5-8(A)(3) vests the Court with jurisdiction over appeals in criminal actions originating in courts of limited jurisdiction, and Section 39-3-3(A)(1) provides defendants with a right to appeal to the Court of Appeals. The Court applied the plain meaning rule to interpret the relevant constitutional and statutory provisions, rejecting the State's narrower definition of "criminal proceeding" and affirming the broad definition of "proceeding" that includes the right to appeal (paras 1-12).