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, Raul Sanchez, was convicted of battery on a peace officer after allegedly striking Deputy DeSantiago with a closed fist. The incident occurred when the Deputy attempted to take the Defendant into protective custody to transport him to a treatment facility, based on the belief that the Defendant posed a threat to himself or others due to intoxication or incapacitation.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that there was insufficient evidence to support the conviction because the act was not intentional. Additionally, contended that the jury instruction was fundamentally flawed for omitting the element of the peace officer's lawful discharge of duties, asserting that the Deputy was not acting lawfully at the time of the incident.
• Plaintiff-Appellee: The specific arguments of the Plaintiff-Appellee are not detailed in the provided text.

Legal Issues

• Whether there was sufficient evidence to support the Defendant's conviction for battery on a peace officer.
• Whether it was fundamental error to omit the element of lawful discharge of duties from the jury instruction.

Disposition

• The Court of Appeals affirmed the district court’s judgment and sentence, convicting the Defendant of battery on a peace officer.

Reasons

• Per ATTREP, J., with MEDINA, J., and YOHALEM, J., concurring:
  The Court found that there was sufficient evidence to support the Defendant's conviction, as the Deputy testified that the Defendant punched him with a closed fist. The Court refused to reweigh evidence on appeal, adhering to precedent that it is the role of the fact-finder to resolve conflicts in testimony and determine credibility (para 2). Regarding the Defendant's motion to amend the docketing statement to include new issues, the Court concluded that the motion was not viable because it did not meet the criteria for establishing good cause for amendment, specifically noting that the issues raised were not properly preserved below nor were they allowed to be raised for the first time on appeal (para 3).
  The Court also addressed the Defendant's argument regarding the omission of the lawful discharge of duties element from the jury instruction, finding no fundamental error. It was determined that the Deputy was within his legal authority to take the Defendant into protective custody for transport to a treatment facility, based on probable cause to believe the Defendant posed a threat to himself or others. The Court relied on existing New Mexico law and precedent to conclude that an officer is engaged in the lawful discharge of duties if acting within the scope of employment, even if the arrest lacks probable cause (paras 4-8).
  The Court was not persuaded by the Defendant's arguments or the authorities from other jurisdictions cited in his opposition. It affirmed the conviction and judgment, concluding that there was sufficient evidence for the conviction and that omitting a lawful discharge instruction was not a fundamental error (para 9).