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 case involves a bar fight at the Dirty Bourbon nightclub in Albuquerque, New Mexico, on May 9, 2015, between the Defendant and the Victim, Dennis Knight. During the altercation, the Victim was stabbed and later treated for his wounds. The Defendant was seen putting two knives, a cowboy hat, and a bloody t-shirt into his car post-fight. A bloody knife and the cowboy hat with the Victim's blood were recovered from the Defendant's vehicle (paras 2-5).

Procedural History

• Appeal from the District Court of Bernalillo County, Alisa A. Hart, District Judge, July 23, 2018: The Defendant was convicted of aggravated battery with a deadly weapon and tampering with evidence.

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by refusing to give a jury instruction for non-deadly force self-defense and contended that the evidence was insufficient to support the conviction for tampering with evidence (para 1).
• Plaintiff-Appellee: Opposed the Defendant’s instruction on non-deadly force self-defense and argued that the evidence was sufficient to support the conviction for tampering with evidence (paras 8, 17-19).

Legal Issues

• Whether the district court committed reversible error by refusing to give the Defendant’s tendered jury instruction for non-deadly force self-defense.
• Whether the evidence presented at trial was sufficient to support the Defendant's conviction for tampering with evidence.

Disposition

• The Court of Appeals affirmed the district court's decisions on both counts: refusing to give the Defendant’s tendered jury instruction for non-deadly force self-defense and the sufficiency of the evidence supporting the conviction for tampering with evidence (para 20).

Reasons

• Per LINDA M. VANZI, Chief Judge (J. MILES HANISEE, Judge, HENRY M. BOHNHOFF, Judge concurring):
  The Court found that the district court did not commit reversible error in refusing the non-deadly force self-defense instruction as the evidence did not support the Defendant's claim of using non-deadly force. The Court reasoned that using a knife to stab someone constitutes deadly force rather than non-deadly force (paras 12-14).
  Regarding the sufficiency of the evidence for tampering with evidence, the Court held that the evidence presented at trial allowed a reasonable jury to infer that the Defendant intended to prevent his apprehension, prosecution, or conviction by taking the knives from the crime scene and putting them in his vehicle. The Court emphasized that the focus should be on the Defendant's specific intent to mislead law enforcement, regardless of the success of such attempts (paras 15-19).