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

• On January 18, 2017, Defendant Elexus Jolaine Groves and Paul Garcia ingested methamphetamine, stole a van, and fled from law enforcement officers, leading to a high-speed chase. The chase ended when Groves ran a stop sign, colliding with another vehicle, resulting in two deaths and one serious injury. Groves and Garcia fled the scene without assisting the victims and later stole another truck to evade capture. Groves was arrested two days after the incident (paras 2-3).

Procedural History

• State v. Groves, 2021-NMSC-003: The Supreme Court reversed the district court's decision to dismiss two counts of first-degree felony murder against Groves, reinstating the charges (para 5).

Parties' Submissions

• Appellant (Defendant): Argued violations of her speedy trial right, improper jury instruction on aggravated fleeing, abuse of discretion in denying motions to exclude a witness and for a change of venue, judicial bias, error in denying motion to suppress a statement, improper sentencing, and incorrect designation of convictions as serious violent offenses under the EMDA (paras 1, 8-47).
• Appellee (State): Defended the trial court's decisions on all counts, including the handling of the speedy trial claim, jury instructions, witness inclusion, venue decision, absence of judicial bias, motion to suppress, sentencing, and designation of offenses under the EMDA.

Legal Issues

• Whether the delay in trial constituted a violation of the Defendant's speedy trial right.
• Whether the jury was properly instructed on the elements of aggravated fleeing.
• Whether the district court abused its discretion in denying motions to exclude a witness and for a change of venue.
• Whether the district court judge exhibited bias against the Defendant.
• Whether the district court erred in denying the motion to suppress a statement made by the Defendant.
• Whether the sentencing was proper and in accordance with the law.
• Whether the designation of convictions as serious violent offenses under the EMDA was correct (paras 8-47).

Disposition

• The Court of Appeals affirmed the district court’s entry of judgment and sentence against the Defendant on all counts (para 48).

Reasons

• YOHALEM, Judge (with IVES, Judge, and BUSTAMANTE, Judge, concurring): Found no striking violation of the Defendant's right to a speedy trial, considering the length of delay, reasons for delay, Defendant's assertion of the right, and lack of particularized prejudice (paras 8-14). Upheld the jury instruction on aggravated fleeing and found sufficient evidence supporting the conviction (paras 15-19). Determined no abuse of discretion in denying the motion to exclude Mr. Garcia as a witness, considering the State's compliance with disclosure duties and lack of material prejudice to the Defendant (paras 20-29). Found no abuse of discretion in denying the motion for a change of venue, noting the district court's efforts to ensure an impartial jury despite pretrial publicity (paras 30-33). Rejected the claim of judicial bias, citing the lack of evidence showing personal bias or predisposition by the judge (paras 34-38). Declared the challenge to the motion to suppress moot, as the statement in question was not admitted at trial (paras 39-41). Dismissed the sentencing argument as based on inapplicable law and found no abuse of discretion in the EMDA designation of offenses as serious violent offenses (paras 42-47).