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 May 20, 2011, Defendant Jess Carpenter and his friend Joe Darras were out drinking at three establishments in Artesia. After leaving the third establishment around 1:30 a.m. on May 21, 2011, they went to Carpenter's house. Between 1:30 a.m. and 2:00 a.m., Carpenter called 911, reporting he had accidentally shot Darras. Upon arrival, deputies found Darras' body in Carpenter's bedroom, having been shot in the head. Carpenter was taken into custody, and his blood alcohol content was found to be 0.116 grams per milliliter. Carpenter was charged with second-degree murder and negligent use of a deadly weapon (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant (Defendant): Argued that there was insufficient evidence to support the fourth element of the jury instruction—that he committed an unlawful act not amounting to a felony. Contended that the State’s failure to prove each element of involuntary manslaughter violated his constitutional right to a jury trial (paras 1, 9).
• Appellee (State): [Not applicable or not found]

Legal Issues

• Whether there was sufficient evidence to support the fourth element of the jury instruction given at trial—that the defendant committed an unlawful act not amounting to a felony.
• Whether the State’s failure to prove each element of involuntary manslaughter implicates the defendant's constitutional right to a jury trial (paras 9, 18).

Disposition

• The Court of Appeals of New Mexico affirmed the Defendant's conviction for involuntary manslaughter (para 22).

Reasons

• The Court, per Judge M. Monica Zamora, with Judges James J. Wechsler and Linda M. Vanzi concurring, held that the evidence was sufficient to support the Defendant's involuntary manslaughter conviction and that the Defendant was not denied his right to a jury trial. The Court reasoned that the Defendant did not dispute the evidence was sufficient for the remaining elements of involuntary manslaughter beyond the contested fourth element. It referenced the Supreme Court's decision in Musacchio v. United States, which clarified how to assess challenges to the sufficiency of evidence when a jury instruction adds an element to the charged crime. The Court concluded that the sufficiency of the evidence should be assessed against the elements of the charged crime, not the additional element included in the jury instruction. The Court found that the State presented sufficient evidence to support the jury’s verdict, noting the Defendant's familiarity with firearms, his impairment due to alcohol, and the circumstances leading to Darras' death. The Court also addressed the Defendant's constitutional argument, stating that the inclusion of an additional element in the jury instruction did not implicate the Defendant's right to a jury trial under the federal constitution. The Court did not engage in a separate analysis under the New Mexico Constitution due to the Defendant's failure to adequately develop an argument for greater protection under it (paras 9-21).