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 the State of New Mexico appealing a district court order that excluded witness Paula Welsh from testifying in the trial of Defendant Shrenna Samuels. The exclusion was based on the State's failure to comply with discovery and scheduling orders, specifically regarding the availability of Ms. Welsh for an in-person interview (para 4).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant (State of New Mexico): Argued that the district court failed to make adequate findings on the record to support the exclusion of witness Paula Welsh (para 1).
• Appellee (Defendant Shrenna Samuels): Filed a notice of noncompliance with discovery and a motion to exclude witnesses, including Ms. Welsh, due to the State's failure to comply with the district court’s scheduling and discovery orders (para 4).

Legal Issues

• Whether the district court abused its discretion by excluding witness Paula Welsh from testifying without making adequate findings on the record to support such exclusion.
• Whether the district court erred in its application of the Harper/Le Mier framework in deciding to exclude the witness.

Disposition

• The Court of Appeals reversed the district court’s order excluding Ms. Welsh as a testifying witness and remanded for further proceedings consistent with the opinion (para 6).

Reasons

• The Court of Appeals, with Chief Judge J. Miles Hanisee authoring the opinion, and Judges Kristina Bogardus and Gerald E. Baca concurring, found that the district court erred by not demonstrating its consideration of the Harper/Le Mier framework on the record. This framework requires the assessment of the culpability of the offending party, the prejudice to the adversely affected party, and the availability of lesser sanctions. The Court noted that the district court's order lacked adequate written findings and failed to articulate its consideration of the prejudice or availability of lesser sanctions factors. The Court emphasized that district courts must explain their decision to exclude or not to exclude a witness within the Harper/Le Mier framework, which was not done in this case (paras 2-5).