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 State failed to disclose the CAD record as required by the deadlines imposed by Second Judicial District Court Local Rule 2-400 NMRA, leading to the district court’s order to dismiss the charges against Defendant Matthew Lee Espinoza without prejudice.

Procedural History

• Appeal from the District Court of Bernalillo County, Alisa Ann Hadfield, District Judge, dismissing the charges against Defendant without prejudice.

Parties' Submissions

• Appellant (State): Argued that it was not required to disclose the CAD record because there was no showing of materiality to the defense. The State also contended that since it had no intention of calling the field investigator as a witness at trial, it did not need to disclose the CAD record (paras 2).
• Appellee (Defendant): [Not applicable or not found]

Legal Issues

• Whether the State was required to disclose the CAD record despite its contention that the record was not material to the defense and that it had no intention of calling the field investigator as a witness at trial.

Disposition

• The Court of Appeals affirmed the district court’s order dismissing the charges against the Defendant without prejudice.

Reasons

• J. MILES HANISEE, Judge, with MICHAEL E. VIGIL, Chief Judge, and STEPHEN G. FRENCH, Judge concurring, found that the State's failure to disclose the CAD record as required by the deadlines imposed by Second Judicial District Court Local Rule 2-400 NMRA was not excused by the State's arguments regarding materiality or its intentions regarding witness testimony. The Court pointed out that Rule 5-501(A)(3) NMRA requires disclosure of evidence material to the preparation of the defense or intended for use by the state as evidence at trial. Furthermore, Local Rule 2-400(D)(1) NMRA mandates the State to provide copies of documentary evidence, including audio, video, and audio-video recordings in possession of the state, at arraignment or within five days of a written waiver of arraignment, without requiring a showing of materiality to the defense. The Court concluded that the plain language of Local Rule 2-400 is broader than that of Rule 5-501(A)(3), requiring the State to provide to the defense copies of documentary evidence irrespective of a showing of materiality (paras 2-3).