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 State sought to appeal a district court's decision that partially granted the Defendant's motion to exclude certain evidence in a case. The evidence in question included the results of a rapid urine drug screen and X-rays. The district court had concerns regarding the foundation, confrontation, and potential prejudice of this evidence. The State argued that these concerns could be alleviated by the testimony of two treating physicians, who were available to testify, but the court excluded the evidence without hearing the physicians' testimony (paras 2-4).

Procedural History

• Appeal from the District Court of Bernalillo County, Charles W. Brown, District Judge, June 19, 2017: The district court granted in part the Defendant's motion to exclude evidence, specifically the results of a rapid urine drug screen and X-rays.

Parties' Submissions

• Plaintiff-Appellant (State): Argued that the substance of the evidence and the grounds for its admissibility were explained to, and understood by, the district court, asserting that an offer of proof was indeed made. The State believed that the evidentiary concerns, especially foundational ones, would be alleviated by the testimony of two treating physicians (paras 3-4).
• Defendant-Appellee: Successfully moved for the exclusion of certain evidence, including the results of a rapid urine drug screen and X-rays, on the grounds of foundational, confrontation, and prejudice concerns (para 3).

Legal Issues

• Whether the district court erred in excluding the results of a rapid urine drug screen.
• Whether the district court erred in excluding X-rays (para 2).

Disposition

• The Court of Appeals affirmed the district court's order granting in part the Defendant's motion to exclude certain evidence (para 6).

Reasons

• Per J. Miles Hanisee, with Timothy L. Garcia and Julie J. Vargas concurring, the Court of Appeals found that the State did not meet its burden on appeal to demonstrate error on the part of the district court in excluding the evidence at issue, where the alleged errors were not preserved by an offer of proof. The State's memorandum in opposition, which included information from a transcript of the hearing on the Defendant's motion in limine, and the district court's exclusion order, indicated that the district court had evidentiary concerns regarding foundation, confrontation, and prejudice for both the X-rays and the rapid drug screening results. The State's failure to make a sufficient offer of proof left an incomplete record for review on appeal. Consequently, the Court of Appeals concluded that the State did not preserve error for appellate review and declined to consider the State’s substantive arguments regarding the district court’s exclusion rulings (paras 2-5).