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 the Defendant, Nathaniel Yazzie, who challenged the validity of his no contest plea on the grounds that "attempted negligently permitting child abuse" is a non-existent crime. This challenge arose after the Defendant entered a plea agreement, which included a provision allowing him to appeal the denial of his motion to suppress evidence obtained under the emergency assistance doctrine.

Procedural History

• State v. Yazzie, 2019-NMSC-008, ¶ 52, 437 P.3d 182: The New Mexico Supreme Court held that the Defendant’s motion to suppress evidence was properly denied by the district court, reversing the Court of Appeals and directing it to address any of Defendant’s remaining arguments.
• State v. Yazzie, No. 34,537, mem. op. (N.M. Ct. App. May 11, 2017): The Court of Appeals' decision was reversed by the New Mexico Supreme Court.

Parties' Submissions

• Plaintiff-Appellee (State of New Mexico): Argued that the Defendant's no contest plea, which was entered voluntarily after advice of counsel and with full understanding of the consequences, waives objections to prior defects in the proceedings and operates as a waiver of statutory or constitutional rights, including the right to appeal.
• Defendant-Appellant (Office of the Public Defender on behalf of Nathaniel Yazzie, deceased): Challenged the validity of the no contest plea, asserting that "attempted negligently permitting child abuse" is a non-existent crime, and therefore, the plea is invalid.

Legal Issues

• Whether the Defendant's no contest plea to a charge of "attempted negligently permitting child abuse," a claimed non-existent crime, is valid.
• Whether the terms of the Defendant's plea agreement limit his right to appeal only to the denial of his motion to suppress evidence.

Disposition

• The Court of Appeals affirmed the decision, concluding that the terms of the Defendant's plea agreement limited his appeal to the denial of his motion to suppress evidence, and given the Supreme Court's affirmation of that denial, the Defendant's appeal on the merits of his plea to the underlying offense was barred.

Reasons

• J. Miles Hanisee, Chief Judge, with Jacqueline R. Medina, Judge, and Katherine A. Wray, Judge, concurring:
  The Court observed that a voluntary guilty or no contest plea generally waives the right to appeal, except on jurisdictional grounds, unless the plea agreement specifies otherwise (para 3).
  The Court analyzed the Defendant's plea agreement, noting that it explicitly limited the scope of appeal to the denial of the motion to suppress. The agreement was interpreted according to what the Defendant reasonably understood at the time of entering the plea, which was found to be a reservation of the right to appeal only the denial of the motion to suppress (paras 4-5).
  Given the Supreme Court's previous decision affirming the denial of the motion to suppress, the Court concluded that the Defendant's appeal on the merits of his plea to the underlying offense was barred by the terms of his plea agreement (para 5).