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

• In early 2013, the Defendant was involved in activities with a minor, B.G., which led to charges of human trafficking, promoting prostitution, accepting earnings from a prostitute, contributing to the delinquency of a minor, and conspiracy. The State's theory was that B.G. engaged in commercial sexual activity at the Defendant's urging and with his assistance, leading to his conviction on all counts by a jury.

Procedural History

• Certiorari Denied, October 15, 2018, No. S-1-SC-37267: The Supreme Court denied certiorari.

Parties' Submissions

• Plaintiff-Appellee: Argued that the Defendant was rightfully convicted based on the evidence presented at trial, including the Defendant's involvement in the commercial sexual exploitation of B.G., a minor.
• Defendant-Appellant: Raised four points of error, arguing that the district court failed to instruct the jury properly on the necessity of knowing the victim's age for a human trafficking conviction, improperly admitted text messages without proper foundation, presented insufficient evidence for conviction, and abused its discretion by denying a motion for a new trial based on new evidence suggesting B.G. lied during her testimony.

Legal Issues

• Whether the jury instructions were adequate in not requiring proof that the Defendant knew B.G. was under the age of eighteen for a human trafficking conviction.
• Whether the district court abused its discretion by admitting text messages without the State laying a proper foundation.
• Whether there was sufficient evidence to convict the Defendant of the charged crimes.
• Whether the district court abused its discretion in denying the Defendant's motion for a new trial based on new evidence.

Disposition

• The Court of Appeals affirmed the Defendant's convictions on all counts.

Reasons

• The Court of Appeals, per Judge Vargas, with Judges Vigil and French concurring, held that:
  Knowledge of the victim's age is not an element of human trafficking under NMSA 1978, Section 30-52-1(A)(2) (2008), as the statute's language indicates that "knowingly" refers to the act of recruiting, soliciting, enticing, transporting, or obtaining, not the victim's age (paras 3-8).
  The district court did not abuse its discretion in admitting the text messages as evidence, finding that the State provided sufficient foundational evidence to authenticate the messages and link them to the Defendant (paras 13-18).
  The evidence presented at trial was sufficient to support the Defendant's convictions on all counts, as it satisfied the elements required for each charge when viewed in the light most favorable to the verdict (paras 22-28).
  The district court did not abuse its discretion in denying the Defendant's motion for a new trial based on newly discovered evidence, as the evidence was considered merely impeaching and not likely to change the trial's outcome (paras 30-34).