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 April 3, 2013, Danielle Smiley entered a trailer to confront Danielle Dixon (Victim) over concerns about the Victim's behavior towards Smiley's father and children in the home. Smiley dragged the Victim from a back room to the living room of the trailer and assaulted her, resulting in serious injuries to the Victim. The Victim was later diagnosed with closed nasal bone fractures and multiple rib fractures, and after a series of hospital visits, died on May 10, 2013, due to blunt force chest trauma (paras 2-5).

Procedural History

• District Court of San Juan County, John A. Dean Jr., District Judge: Convicted Danielle Smiley of kidnapping in the first degree and aggravated battery with great bodily harm. The jury was unable to reach a verdict on the second-degree murder charge, leading to a mistrial for that charge (para 6).

Parties' Submissions

• Appellant (Danielle Smiley): Argued that the kidnapping conviction should be reversed because the movement of the Victim from one room to another was incidental to the commission of aggravated battery. Also contended that the district court erred in denying requested jury instructions on self-defense, excluding certain statements as hearsay, and claimed ineffective assistance of counsel for not requesting a necessity instruction (paras 1, 7, 13, 20-21).
• Appellee (State of New Mexico): [Not applicable or not found]

Legal Issues

• Whether the brief movement of the Victim from one room to another constitutes kidnapping or was incidental to the commission of aggravated battery.
• Whether the district court erred in denying the appellant's requested jury instructions on self-defense.
• Whether certain statements were improperly excluded as hearsay.
• Whether the appellant's trial counsel was ineffective for not requesting a necessity instruction (paras 7, 13, 20-21).

Disposition

• The kidnapping conviction was vacated.
• The conviction for aggravated battery was affirmed.
• The district court's decisions on jury instructions, hearsay exclusion, and the claim of ineffective assistance of counsel were upheld (paras 22-23).

Reasons

• LINDA M. VANZI, Chief Judge (JONATHAN B. SUTIN, Judge, J. MILES HANISEE, Judge concurring): The court agreed with the appellant that the movement of the Victim was incidental to the commission of aggravated battery and vacated the kidnapping conviction. It was determined that the movement did not substantially increase the risk of harm to the Victim beyond that inherent in the battery, nor was it significant enough to warrant independent prosecution for kidnapping. The court disagreed with the appellant on the remaining points, finding no error in the district court's denial of jury instructions on self-defense, as the appellant initiated the confrontation without evidence of immediate bodily harm or fear. The court also found the appellant's arguments regarding hearsay exclusion and ineffective assistance of counsel either moot or unsupported by argument or facts (paras 7-21).