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Facts

  • On December 1, 2008, a Bernalillo County Sheriff’s Office Deputy discovered a wrecked Jeep Cherokee by the side of Highway 217 in Bernalillo County, New Mexico, with Darla Bregar and Thomas Spurlin found on the ground near the Jeep. Bregar was on the driver’s side, and Spurlin was deceased on the passenger side. Bregar admitted to driving the vehicle the night before but did not remember the crash. Her blood alcohol concentration was found to be 0.09 at the time of the blood draw. Bregar was charged with vehicular homicide and per se DWI. At trial, Bregar claimed she could not have been driving due to wearing a knee brace that would have prevented her from operating a vehicle, suggesting Spurlin was the driver.

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Plaintiff-Appellee (State of New Mexico): Argued that Bregar was driving the vehicle under the influence of alcohol, which led to the crash and Spurlin's death. Presented evidence of Bregar's blood alcohol concentration and her admission of driving the vehicle.
  • Defendant-Appellant (Darla Bregar): Contended she could not have been driving due to a knee brace and suggested Spurlin was the driver. Argued her hospital-bed statements were not voluntarily made and challenged the admission of expert opinion testimony by Deputy Garcia.

Legal Issues

  • Whether the defendant's hospital-bed statements to police officers were voluntarily made and admissible in court.
  • Whether the district court erred in admitting Deputy Garcia's expert opinion testimony regarding the accident reconstruction.
  • Whether sufficient evidence was presented to establish the corpus delicti of vehicular homicide.

Disposition

  • The district court’s denial of Bregar’s pretrial motion to suppress her hospital-bed admissions was upheld.
  • The district court did not commit plain error by admitting Deputy Garcia’s expert opinion testimony.
  • The challenge to the sufficiency of the evidence supporting a corpus delicti was rejected.

Reasons

  • The Court found Bregar’s hospital-bed statements were voluntarily made under the totality of the circumstances test, considering the external facts, the defendant's reaction to those facts, and the legal significance of the reaction (paras 5-7). The Court also held that the district court did not commit plain error in admitting Deputy Garcia’s expert testimony regarding the accident reconstruction, despite challenges to his qualifications and methodology (paras 26-44). Finally, the Court concluded that there was sufficient independent evidence, apart from Bregar’s admissions, to establish the corpus delicti of vehicular homicide, including the position of the driver’s seat and the fact that Bregar was the vehicle's owner and licensed to drive (paras 45-49).
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