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Facts

  • The State charged the Child with multiple offenses, including shooting at or from a motor vehicle and aggravated battery with a deadly weapon. An initial hearing was set, but due to the COVID-19 pandemic and technical difficulties, the Child appeared by phone, preventing witness identification. A continuance was granted, extending the timeline beyond the statutory limit for a probable cause determination. The Child filed a motion to quash based on this delay, which the district court denied, citing the pandemic as an exceptional circumstance (paras 2-3).

Procedural History

  • Appeal from the District Court of Taos County, Jeffrey A. Shannon, District Judge: The district court denied the Child's emergency motion to quash or dismiss the State’s notice of intent to seek adult sanctions, finding the COVID-19 pandemic an exceptional circumstance justifying an extension of time.

Parties' Submissions

  • Child-Appellant: Argued that the COVID-19 pandemic did not constitute an "exceptional circumstance" justifying the extension of time under Rule 10-213(D) and that the State had an affirmative obligation to request a hearing within the thirty-day timeline (para 4).
  • Plaintiff-Appellee (State): Contended that the COVID-19 pandemic was an exceptional circumstance that justified extending the deadline for making a probable cause determination under Rule 10-213 (para 8).

Legal Issues

  • Whether the COVID-19 pandemic constitutes an "exceptional circumstance" under Rule 10-213(D), justifying an extension of the deadline for making a probable cause determination (para 4).

Disposition

  • The Court of Appeals affirmed the district court's decision, holding that the COVID-19 pandemic and its precautionary measures were exceptional circumstances warranting an extension of time to make a probable cause determination under Rule 10-213(B) (para 12).

Reasons

  • Per B. Zamora, J. (J. Miles Hanisee, C.J., and Jacqueline R. Medina, J., concurring): The court reviewed the district court's interpretation of procedural rules de novo and its decision to grant an extension under an abuse of discretion standard. It found that the COVID-19 pandemic, being an unforeseeable and extraordinary public health crisis, constituted an exceptional circumstance. The court noted that the pandemic's impact on court operations and the specific issues arising from the need for social distancing and technical difficulties at the preliminary hearing were beyond the control of the parties and the court. The court also rejected the Child's argument that the State had failed to meet its obligations, noting that the extension was requested by the Child's defense and that the pandemic's effects were unforeseeable and extraordinary (paras 4-11).
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