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 battery upon a peace officer, battery against a household member, and resisting, evading, or obstructing an officer after a jury trial. The charges arose from an incident where the Defendant, found intoxicated while caring for her young children, engaged in a physical altercation with Ricky Smith, her partner, and subsequently resisted arrest and assaulted a peace officer during the police intervention (paras 1, 5-6).

Procedural History

• Appeal from the District Court of San Juan County, William C. Birdsall, District Judge, October 14, 2014.

Parties' Submissions

• Defendant: Argued that the district court erred by not granting a directed verdict on the battery upon a peace officer charge due to lack of evidence of actual injury or threat to Officer Brown. Contended that evidence of her intoxication and threats towards her children was inadmissible bad character evidence and prejudicial. Argued that her prior felony conviction for child abuse should not have been used for impeachment, and that her rights against double jeopardy were violated due to unitary conduct being charged as separate offenses (paras 2, 5, 8, 13).
• Plaintiff-Appellee (State of New Mexico): [Not applicable or not found]

Legal Issues

• Whether the district court erred in not granting a directed verdict on the battery upon a peace officer charge.
• Whether the district court erred in denying the motion in limine and objections to exclude evidence of Defendant's intoxication and threats towards her children.
• Whether the district court erred by allowing impeachment of the Defendant with her prior felony conviction for child abuse.
• Whether Defendant's rights against double jeopardy were violated by convicting her of both resisting, evading, or obstructing an officer and battery upon a peace officer for unitary conduct.

Disposition

• Affirmed the district court's judgment, sentence, order partially suspending sentence, and commitment to the San Juan County Detention Center on all counts (para 1).

Reasons

• CYNTHIA A. FRY, Judge (JONATHAN B. SUTIN, Judge, J. MILES HANISEE, Judge concurring):
  The Court found that the jury could reasonably infer actual injury or threat to Officer Brown's safety from the Defendant's actions, affirming the conviction for battery upon a peace officer (paras 2-4).
  The Court held that evidence of Defendant's intoxication and threats towards her children was relevant and probative to the State's burden of proving the battery charges, finding no abuse of discretion in its admission (paras 5-7).
  The Court affirmed the district court's decision to allow impeachment of the Defendant with her prior felony conviction for child abuse, finding it relevant to her credibility and not overly prejudicial given the nature of the charges in this case (paras 8-11).
  The Court concluded that Defendant's double jeopardy rights were not violated, as the conduct leading to the charges of resisting, evading, or obstructing an officer and battery upon a peace officer was not unitary, thus affirming the convictions on both counts (paras 13-20).