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 identified as the perpetrator of a residential burglary by an eyewitness during an in-court preliminary hearing. This identification was challenged by the Defendant on the grounds of being unduly suggestive and in violation of his right to due process (paras 3-4).

Procedural History

• State v. Martinez, A-1-CA-36552, mem. op. (N.M. Ct. App. December 23, 2019): The Court of Appeals affirmed the Defendant's conviction for residential burglary, finding sufficient indicia of reliability in the eyewitness identification despite its suggestiveness (para 6).

Parties' Submissions

• Defendant-Petitioner: Argued that the eyewitness identification was unduly suggestive and violated his right to due process. He sought to suppress the identification and later petitioned for the reversal of the Court of Appeals' decision, arguing that the appellate court improperly weighed the reliability factors of the identification (paras 4, 7).
• Plaintiff-Respondent: Defended the trial court's decision to deny the motion to suppress the eyewitness identification and supported the Court of Appeals' affirmation of the conviction. The Respondent argued that the identification had sufficient reliability and that federal due process protections do not apply to in-court identifications by prosecutors (paras 6, 10).

Legal Issues

• Whether the eyewitness identification of the Defendant was unduly suggestive and violated his right to due process (para 4).
• Whether the Court of Appeals improperly weighed the factors bearing on the reliability of the eyewitness identification (para 7).
• Whether federal due process protections apply to eyewitness identifications elicited in court by prosecutors (para 10).

Disposition

• The decision of the Court of Appeals is affirmed (para 15).

Reasons

• Justices Michael E. Vigil, C. Shannon Bacon, David K. Thomson, and Briana H. Zamora unanimously concluded that the Defendant did not adequately preserve the issue for review by failing to cite any provision of the New Mexico Constitution or assert why it provides greater due process protection than the United States Constitution. The Court also noted that federal due process protections do not apply to eyewitness identifications elicited in court by prosecutors. As a result, the Court affirmed the decision of the Court of Appeals by non-precedential order (paras 9-14).