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 case involves a violent confrontation where the Defendant, Thomas Stevenson, and a Codefendant, Oshay Toney, fired more than twenty shots into an SUV driven by Marvin Ellis (Victim), resulting in the Defendant's conviction for shooting at a motor vehicle (great bodily harm) and aggravated assault with a deadly weapon. The Defendant claimed he acted in self-defense or defense of others, believing the SUV had run over someone and was threatening others, including children in a nearby house. The State presented evidence contradicting the Defendant's claims, showing the SUV was backing out of the driveway when the shooting began (para 2).

Procedural History

• District Court of Bernalillo County: Convicted the Defendant of felony murder, voluntary manslaughter, shooting at a motor vehicle resulting in great bodily harm, and aggravated assault with a deadly weapon. The felony murder and voluntary manslaughter convictions were later vacated on legal grounds not relevant to this opinion (para 2).

Parties' Submissions

• Defendant: Argued that he acted in self-defense or defense of others, believing the SUV posed a threat. Claimed the best evidence rule was violated by admitting testimony about text messages without presenting the messages themselves. Contended that extraneous information may have reached the jury, and alleged a Brady violation due to the State's failure to disclose the arrest of a key witness post-testimony (paras 3, 9, 13).
• State: Presented evidence contradicting the Defendant's version of events, indicating the SUV was not a threat when the shooting started. Argued that the best evidence rule was not violated, as diligent efforts were made to access the text messages. Opposed the Defendant's motion for an evidentiary hearing regarding extraneous information reaching the jury and contended that the Defendant did not preserve the Brady issue for appeal (paras 4-8, 10-12, 14-18).

Legal Issues

• Whether the best evidence rule required the original text messages to be produced at trial instead of testimony about their content (para 3).
• Whether extraneous information improperly reached the jury, warranting an evidentiary hearing (para 9).
• Whether a Brady violation occurred due to the State's failure to disclose the arrest of a key witness post-testimony (para 13).
• Whether evidence of prior violent conduct by the Victim was admissible under self-defense claims, and if the State's response was limited to reputation or opinion evidence (para 21).

Disposition

• The Court affirmed the Defendant's convictions for shooting at a motor vehicle (great bodily harm) and aggravated assault with a deadly weapon (para 1).

Reasons

• The Court found that the State made diligent efforts to access the original text messages, thus not violating the best evidence rule (paras 4-8). It determined that the Defendant did not make a preliminary showing that extraneous information reached the jury, thus not warranting an evidentiary hearing (paras 10-12). On the Brady issue, the Court concluded it was not preserved for appeal as the Defendant's motion did not sufficiently raise a Brady claim (paras 14-18). Regarding the admissibility of evidence of the Victim's prior violent conduct, the Court agreed with the Defendant's interpretation that only reputation or opinion evidence could be introduced by the State in response to the Defendant's self-defense claim, but found no reversible error as the Defendant was allowed to present some evidence of the Victim's violent history and did not preserve the argument of being inhibited from introducing additional evidence (paras 21-33).