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 stopped for driving significantly over the speed limit and subsequently arrested for driving while intoxicated (DWI). Initially charged with a third-degree felony DWI, the charge was dismissed without prejudice to allow further investigation into the Defendant's prior offenses. The Defendant then pleaded no contest to the speeding charge. Later, the State re-filed the DWI charge as a misdemeanor second offense based on the investigation's findings (paras 2-4).

Procedural History

• District Court of Santa Fe County: The misdemeanor DWI conviction in a de novo bench trial was upheld, and the Defendant's motion to dismiss based on the compulsory joinder rule was denied.

Parties' Submissions

• Defendant-Appellant: Argued that the misdemeanor DWI charge should have been dismissed because it was not joined with the speeding citation as required by the compulsory joinder rule, Rule 5-203(A) NMRA (paras 4-6).
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the compulsory joinder rule, Rule 5-203(A) NMRA, required the DWI charge and traffic citation to be joined, and if its non-application was an error (para 1).

Disposition

• The Court of Appeals held that the compulsory joinder rule did not require the DWI charge and traffic citation to be joined in this case, affirming the district court's decision to deny the Defendant's motion to dismiss (para 10).

Reasons

• SUTIN, Judge: Concluded that Rule 5-203(A) did not necessitate the joinder of the DWI and traffic offense because they were not of the same or similar character nor based on the same conduct. The decision was also supported by standards and principles outside the compulsory joinder rule, indicating that a no contest plea to a lesser offense does not bar subsequent prosecution for a greater offense related to the same episode (paras 8-10).
  VIGIL, Chief Judge (specially concurring): Agreed that Rule 5-203(A) did not apply, but for the reason that there was no traffic offense to join with the DWI charge in the district court, as the speeding case was resolved before the DWI charge was re-filed. Emphasized that at the time of the Defendant's motion to dismiss in the district court, only the DWI charge was pending, making the compulsory joinder rule inapplicable (paras 12-16).