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 Defendant, Jessica Brown, who was convicted of one count of battery upon a peace officer and one count of resisting, evading, or obstructing an officer following a jury trial. The convictions stemmed from an incident involving Albuquerque Police Officer Daniel Sanchez, who made a warrantless entry into Brown's home. Officer Sanchez entered the home without a warrant due to concerns for the safety of Brown's child, who had been observed on the roof of the house. The situation escalated, leading to Brown's actions that resulted in her charges and subsequent convictions (paras 1, 4-5).

Procedural History

• Appeal from the District Court of Bernalillo County, Cristina T. Jaramillo, District Judge: Conviction of Defendant for one count of battery upon a peace officer and one count of resisting, evading, or obstructing an officer following a jury trial.

Parties' Submissions

• Plaintiff-Appellee (State of New Mexico): Argued that the evidence of Defendant’s violence or threatened violence toward police officers subsequent to an unlawful search or seizure or a warrantless entry should not be suppressed and that the Defendant's actions constituted new criminal activity not subject to the exclusionary rule.
• Defendant-Appellant (Jessica Brown): Contended that the warrantless entry by Officer Sanchez was unlawful and challenged the district court's decisions on several grounds, including the legality of the entry, discovery violations, and the sufficiency of evidence. Brown also argued that she was entrapped by Officer Sanchez's actions, which led to her committing the offenses.

Legal Issues

• Whether the district court erred in denying the Defendant's motion to dismiss or suppress based on an illegal warrantless entry.
• Whether the district court erred in failing to sanction the State for discovery violations.
• Whether the evidence was sufficient to support the guilty verdicts.
• Whether the Defendant received ineffective assistance of counsel.
• Whether the district court erred in denying the Defendant's request for an instruction on entrapment.

Disposition

• The Court of Appeals affirmed the district court’s judgment, sentence, and commitment, convicting the Defendant of one count of battery upon a peace officer and one count of resisting, evading, or obstructing an officer (para 1).

Reasons

• Per Michael E. Vigil, Chief Judge (James J. Wechsler, Judge, and Stephen G. French, Judge, concurring):
  The Court found that although Officer Sanchez's warrantless entry into the Defendant's home was unlawful, the evidence of the Defendant's subsequent actions (battery upon a peace officer and resisting arrest) was not subject to suppression. This decision was based on jurisprudence rejecting the suppression of evidence relating to a defendant’s violence or threatened violence toward police officers following an unlawful entry. The Court also addressed the Defendant's entrapment defense, concluding that the Defendant was not entitled to an entrapment instruction regarding the battery charge, as it appeared she denied committing the offense. Regarding the resisting arrest charge, the Court found no evidence that Officer Sanchez's actions constituted entrapment. The Court remained unpersuaded by the Defendant's arguments against the proposed disposition, including her agreement with the Court's conclusion regarding the unlawfulness of the entry but failure to provide compelling arguments or authority to support a different outcome on the issues of new criminal activity jurisprudence and entrapment (paras 3-13).