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 unlawful assault on a jail, challenging the charge and conviction on the basis that the crime historically aimed to deter unauthorized physical invasions into a jail's territory.

Procedural History

• State v. Anderson, 2021-NMCA-031, 493 P.3d 434, cert. granted, 2021-NMCERT____ (No. S-1-SC-38782, June 28, 2021): The court conducted a full statutory analysis of Section 30-22-19, including its historical basis, applied a constitutional vagueness test, and upheld Section 30-22-19.

Parties' Submissions

• Defendant-Appellant: Argued that he was improperly charged and convicted of assault on a jail, contending that the statute's purpose has always been to deter unauthorized physical invasions into a jail's territory. The Defendant requested the court to overturn the recent holding in State v. Anderson.
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the Defendant was improperly charged and convicted of assault on a jail based on the argument that the statute's historical purpose was to deter unauthorized physical invasions into a jail's territory.
• Whether to overturn the court's recent holding in State v. Anderson regarding the interpretation of Section 30-22-19.

Disposition

• The appeal was denied, and the conviction of unlawful assault on a jail was affirmed.

Reasons

• Per HANISEE, Chief Judge (DUFFY, Judge and HENDERSON, Judge concurring): The court found the Defendant's arguments to be without merit, citing the precedent set in State v. Anderson, which conducted a thorough analysis of Section 30-22-19 and upheld its constitutionality. The court concluded that nothing in the jurisprudence or the language of the statute itself requires an external invasion into the physical boundaries of the jail for the purpose of procuring the escape of prisoners or similarly interfering with the lawful confinement of prisoners. The decision in Anderson was determined to control the present case, leading to the affirmation of the Defendant's conviction (paras 1-2).