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 was involved in an altercation with police officers, resulting in charges of battery upon a peace officer, resisting, evading, or obstructing an officer, and criminal trespass. The incident included a physical confrontation where the Defendant allegedly kicked Officer Tyler Sanchez and was irate and noncompliant throughout the encounter. Additionally, the Defendant was accused of criminal trespass at the New Mexico Bank and Trust after being told to leave the property by a security guard and returning later, attempting to use the ATM.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by allowing the State to amend the information to change the alleged victim's name in the battery charge and contended that the convictions for battery upon a peace officer and criminal trespass were not supported by sufficient evidence. The Defendant also claimed prejudice due to the amendment of the information, asserting it precluded full preparation for the new charge and denied the opportunity to fully investigate a new theory of the case.
• Plaintiff-Appellee (State of New Mexico): Defended the amendment of the information and the sufficiency of the evidence for the convictions, arguing that the Defendant was not prejudiced by the amendment as he had prior notice of Officer Casias's involvement and access to evidence related to the altercation. The State maintained that the evidence presented at trial was sufficient to support the convictions.

Legal Issues

• Whether the district court erred in allowing the State to amend the information to change the alleged victim's name in the battery charge.
• Whether there was sufficient evidence to support the Defendant's convictions for battery upon a peace officer and criminal trespass.

Disposition

• The Court of Appeals affirmed the Defendant's convictions for battery upon a peace officer, resisting, evading, or obstructing an officer, and criminal trespass.

Reasons

• Per Yohalem, J. (Duffy, J., and Wray, J., concurring):
  The Court found no error in the district court's decision to allow the State to amend the information, as the Defendant failed to establish any prejudice resulting from the amendment. The Defendant had prior notice of Officer Casias's involvement, access to evidence, and the opportunity for additional pretrial preparation, including the option to reinterview Officer Casias (paras 2-5).
  On the issue of sufficiency of the evidence, the Court held that viewing the evidence in the light most favorable to the State, there was sufficient evidence to support the jury's verdicts. For the battery charge, evidence included Officer Sanchez's testimony about the altercation and the Defendant's aggressive behavior. For the criminal trespass charge, evidence showed the Defendant's unauthorized presence at the New Mexico Bank and Trust, despite being told to leave by a security guard (paras 8-16).
  The Court concluded that the Defendant's conduct during the altercation with Officer Sanchez constituted a meaningful challenge to the officer's authority, supporting the battery charge. Additionally, the Defendant's actions at the New Mexico Bank and Trust met the criteria for criminal trespass, as he remained on the property without permission and after being informed that permission to remain had been withdrawn (paras 12, 16).