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, Raymond Cervantes, entered a guilty plea to trafficking cocaine under a repeat offender plea and disposition agreement. Before sentencing, he sought to withdraw his plea, which the district court denied. Subsequently, the Defendant was charged with additional crimes in another case, where a different judge found him not competent to stand trial based on an expert's testimony regarding his intellectual disability. This memorandum opinion addresses the Defendant's appeal from the district court's judgment, sentence, partially suspended sentence, and commitment, arguing errors related to the plea agreement, his intellectual disability, and mental incompetency (paras 1-3).

Procedural History

• District Court of Bernalillo County, Charles W. Brown, District Judge: Denied Defendant's motion to withdraw his guilty plea and motion for reconsideration. Denied Defendant's request for an interlocutory appeal.
• Court of Appeals of New Mexico, April 18, 2016: Current appeal.

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by taking new evidence of guilt contrary to the plea agreement, that charges must be dismissed due to his intellectual disability and mental incompetency, and that the State is estopped from denying his mental incompetence due to previous stipulations to dismiss other criminal actions against him (para 1).
• Plaintiff-Appellee (State): Agreed with the Defendant that the case should be remanded for a factual determination of the Defendant's competency (para 5).

Legal Issues

• Whether the district court erred by taking new evidence of additional guilt based on probable cause contrary to the plea agreement.
• Whether the charges against the Defendant must be dismissed based on his intellectual disability and mental incompetency.
• Whether the State is estopped to deny the Defendant's mental incompetence as a result of the State’s stipulation to dismissals of other criminal actions against him.

Disposition

• The case is remanded to the district court for a determination as to the Defendant's competency to stand trial. Should the district court determine that the Defendant was competent to stand trial, the sentencing by the district court is affirmed (para 10).

Reasons

• JAMES J. WECHSLER, Judge (MICHAEL D. BUSTAMANTE, Judge, M. MONICA ZAMORA, Judge concurring): The court found that the Defendant's appeal raised significant issues regarding the adherence to the plea agreement and his competency to stand trial due to intellectual disability. The court agreed with both parties that a remand for a factual determination of the Defendant's competency was appropriate, citing statutory requirements for suspension of proceedings in cases where competency is in question. The court also noted that if the Defendant is found competent, the sentencing decisions made by the district court, including the habitual offender enhancement based on violations of conditions of release, stand affirmed. The court highlighted that the plea agreement allowed for habitual offender proceedings if the Defendant violated any law or condition of release, which included failing to appear for scheduled court hearings or leaving the county without permission, both of which the Defendant did (paras 4-9).