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

• In early February 2012, the Defendant was involved in a single-vehicle accident after hitting a curb and parked his vehicle behind an apartment building before leaving the scene. An officer dispatched to the scene was informed by a witness about the Defendant's location. Upon interaction, the Defendant exhibited signs of alcohol consumption. After failing field sobriety tests, he was arrested for DUI. The breath alcohol test (BAT) administered showed results of .14 and .13, leading to his conviction for DUI and leaving the scene of an accident (paras 2-9).

Procedural History

• District Court of Bernalillo County, Christina P. Argyres, District Judge: Affirmed the Metropolitan Court conviction for DUI and leaving the scene of an accident.

Parties' Submissions

• Defendant-Appellant: Argued that the trial court erred in admitting the BAT results due to the State's failure to establish that the equipment used was approved by the Scientific Laboratory Division. Also contended that he did not violate the statute for leaving the scene of an accident (paras 1, 11).
• Plaintiff-Appellee (State): Conceded that the jury instruction on leaving the scene of an accident resulted in fundamental error but did not object to the reversal on this issue. Defended the admission of the BAT results (para 13).

Legal Issues

• Whether the trial court abused its discretion in admitting the BAT results without the State meeting the foundational requirement for equipment approval by the Scientific Laboratory Division.
• Whether there was sufficient evidence to support the Defendant's conviction for leaving the scene of an accident (paras 11, 14).

Disposition

• Affirmed the Defendant's conviction for DUI.
• Reversed the Defendant's conviction for leaving the scene of an accident (para 21).

Reasons

• The Court, comprising Judges Linda M. Vanzi, James J. Wechsler, and Timothy L. Garcia, held that the State did not need to prove that the equipment attached to the Intoxilyzer 8000 was approved by the Scientific Laboratory Division for the BAT results to be admissible, aligning with the precedent set in State v. Hobbs. Therefore, the admission of the Defendant's BAT results was not an abuse of discretion. However, the Court agreed with the State's concession that the jury instruction on leaving the scene of an accident was fundamentally flawed as it did not require the jury to find that another vehicle was involved. Given the statutory requirement for an accident involving at least two vehicles, the conviction for leaving the scene of an accident was reversed (paras 11-22).