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, after shooting the victim, threw the gun before fleeing the scene. This act led to his conviction for tampering with evidence under NMSA 1978, Section 30-22-5 (2003).

Procedural History

• State v. Rodriguez, A-1-CA 35,934, mem. op. ¶ 17 (N.M. Ct. App. Dec. 23, 2019): The Court of Appeals vacated Defendant Daryl Rodriguez’s tampering with evidence conviction on grounds of insufficient evidence.

Parties' Submissions

• Plaintiff-Petitioner (State of New Mexico): Argued that the evidence presented was sufficient for a conviction of tampering with evidence, as it showed the Defendant's specific intent through his actions after the shooting.
• Defendant-Respondent (Daryl Rodriguez): [Not applicable or not found]

Legal Issues

• Whether the evidence presented at trial was sufficient to support the Defendant's conviction for tampering with evidence under NMSA 1978, Section 30-22-5 (2003).

Disposition

• The decision of the Court of Appeals is reversed, and Defendant’s conviction for tampering with evidence under Section 30-22-5 is reinstated.

Reasons

• Per MICHAEL E. VIGIL, Chief Justice; C. SHANNON BACON, Justice; DAVID K. THOMSON, Justice; JULIE J. VARGAS, Justice: The Court determined that the State presented sufficient evidence of an overt act from which the jury could infer the Defendant's specific intent to tamper with evidence, specifically citing testimony that the Defendant threw the gun before fleeing the scene after shooting the victim. This decision was based on the principle that a jury verdict supported by substantial evidence should not be disturbed on appeal and that the appellate court may not substitute its judgment for that of the jury. The Court also exercised its discretion to dispose of the case by non-precedential order rather than by formal opinion (paras 1-7).