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, Matias Loza, was associated with the AZ Boys, a group primarily involved in distributing methamphetamine. Following a home invasion investigation, law enforcement found a vehicle on fire with a deceased person inside, identified as Richard Valdez, linked to the AZ Boys. The Defendant was found nearby, appeared nervous, and smelled of gasoline. He was taken into custody, where he attempted to bribe an officer for his release. The Defendant was indicted for racketeering, conspiracy to commit racketeering, among other charges, with the latter two proceeding to trial (paras 2-7).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant (Defendant): Argued that the district court improperly admitted evidence of uncharged crimes, wrongs, or other acts, and that the admission of an audio recording transcript identifying Defendant's voice by a detective was improper due to insufficient familiarity with the voices recorded (paras 1, 21).
• Appellee (State): Contended that the evidence of uncharged crimes was intrinsic to the charges of racketeering and conspiracy to commit racketeering, making Rule 11-404(B) NMRA inapplicable. Additionally, argued that the detective was sufficiently familiar with the recorded voices to make identifications under New Mexico law (paras 1, 21).

Legal Issues

• Whether the district court improperly admitted evidence of uncharged crimes, wrongs, or other acts under Rule 11-404(B) NMRA in a case involving charges of racketeering and conspiracy to commit racketeering (para 1).
• Whether the district court improperly admitted the transcript of an audio recording identifying Defendant's voice among others, based on a detective's testimony (para 1).

Disposition

• The Court of Appeals affirmed the district court's decision, finding no abuse of discretion in the admission of evidence related to uncharged crimes and the transcript of the audio recording (para 27).

Reasons

• Per WECHSLER, J. (BUSTAMANTE, J., HANISEE, J., concurring):
  The Court held that Rule 11-404(B) NMRA does not apply to evidence of predicate offenses intrinsic to charges of racketeering and conspiracy to commit racketeering. Since the racketeering statute defines violations by reference to predicate offenses, evidence of these offenses is essential and intrinsic to a racketeering charge, making the rule inapplicable (paras 13-20).
  Regarding the audio recording, the Court found that Detective Picazo had sufficient familiarity with the Defendant's voice and those of other AZ Boys members to identify them on the recording. This familiarity was established through multiple interactions and monitoring of telephone conversations, meeting the minimal showing required for voice identification under Rule 11-901(B)(5) NMRA. The Court concluded that any inability to differentiate among speakers in certain segments of the recording affected the weight of the evidence, not its admissibility (paras 21-26).