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 charged with two counts of battery upon a peace officer, one count of battery, and one count of assault following an incident at a convenience store. After a first trial, the Defendant was found guilty of assault, not guilty of battery, and the jury could not reach a decision on the battery upon a peace officer charges. The State retried the Defendant on the latter charges, resulting in a conviction for both counts (paras 1-3).

Procedural History

• District Court of Santa Fe County: The jury found Defendant guilty of assault, not guilty of battery, and could not reach a unanimous decision on the two counts of battery upon a peace officer. The State retried Defendant on the unresolved charges, leading to a conviction (para 1).

Parties' Submissions

• Defendant-Appellant: Argued that (1) the district court erred by allowing the victim of assault to testify at the second trial, (2) the jury instructions were fundamentally erroneous as they did not require a finding that the Defendant did not act in self-defense and included an intoxication instruction not warranted for a general intent crime, and (3) there was insufficient evidence to support the convictions for battery upon a peace officer (para 2).
• Plaintiff-Appellee (State): Contended that the victim's testimony was relevant to show why officers were on the scene, the jury instructions were appropriate, and there was sufficient evidence to support the convictions for battery upon a peace officer (paras 5, 9, 14, 19, 25, 34, 40).

Legal Issues

• Whether the district court abused its discretion by allowing the victim of assault to testify at the second trial.
• Whether the jury instructions were fundamentally erroneous.
• Whether there was sufficient evidence to support the Defendant's convictions for battery upon a peace officer.

Disposition

• The Court of Appeals affirmed both of the Defendant's convictions for battery upon a peace officer (para 57).

Reasons

• The Court of Appeals, per Judge Michael D. Bustamante, with Judges Jonathan B. Sutin and Cynthia A. Fry concurring, held that:
  Regarding the victim's testimony: The district court did not abuse its discretion by allowing the victim to testify as her testimony was relevant to the context of the matter, providing background on why the police officers responded to the convenience store and establishing the Defendant's state of mind (paras 5, 9, 14, 19).
  On jury instructions: The Court found no fundamental error in the jury instructions. Although the instructions did not comply with UJI 14-5185 Use Note 1 by failing to include a statement that the Defendant did not act in self-defense, this omission did not rise to the level of fundamental error. The intoxication instruction, while potentially confusing, did not constitute fundamental error as it placed a higher burden on the State (paras 25-39).
  Sufficiency of the evidence: The Court concluded that there was sufficient evidence for a rational jury to find beyond a reasonable doubt that the Defendant intentionally touched or applied force to the officers, thereby threatening their safety, challenging their authority, or causing actual injury. The evidence supported the convictions for battery upon a peace officer (paras 40-56).