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

• Joseph Hernandez and Catherine Hernandez, a married couple, were convicted of Medicaid fraud and falsification of documents after a jury trial. They had testified before the grand jury that indicted them, represented by the same attorney. Despite waiving any conflict from joint representation and not pursuing a motion to sever their trials, they were tried together. During the trial, their grand jury testimony was introduced by the State over their objections, raising issues under Bruton v. United States.

Procedural History

• Appeal from the District Court of Santa Fe County, Michael E. Vigil, District Judge.

Parties' Submissions

• Appellant Joseph Hernandez: Argued against the admissibility of grand jury testimony, citing Bruton issues and the Confrontation Clause.
• Appellant Catherine Hernandez: Echoed the arguments made by Joseph Hernandez regarding the admissibility of grand jury testimony and Bruton issues.
• Appellee (State of New Mexico): Intended to introduce documents prepared for Medicaid reimbursement and both Defendants’ grand jury testimony, asserting their relevance and admissibility.

Legal Issues

• Whether the motion in limine filed by Defendants preserved the Bruton issue for appeal.
• Whether a Bruton violation requires more than just a co-defendant’s statement.
• Whether Defendants demonstrated that any statement made by either Defendant runs afoul of Bruton.
• Whether it was error not to give mistake of fact and good faith instructions.
• Whether Medicaid fraud is a specific intent crime.
• Whether the district court erred in allowing transcripts of Defendants’ grand jury testimony to go to the jury.

Disposition

• The court affirmed the district court’s rulings, finding no error in its decisions.

Reasons

• The court concluded that the motion in limine did not preserve the Bruton issue for appeal due to its contingent nature and lack of specificity (paras 5-8). It was determined that a Bruton violation requires more than just a co-defendant’s statement, and the Defendants failed to demonstrate that any specific statement made by either Defendant was directly inculpatory of the other (paras 9-15). The court also found that the Defendants did not properly state the elements of Medicaid fraud in their requested instruction and that no instruction on mistake of fact was needed due to the instructions given correctly identifying the specific intent required to commit Medicaid fraud (paras 19-28). Additionally, the court held that it was not error for the district court to allow transcripts of Defendants’ grand jury testimony to go to the jury, as Defendants failed to demonstrate prejudice from this action (paras 30-33).