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 indicted on charges including aggravated burglary, aggravated battery, and conspiracy. The district court dismissed all charges due to a violation of the "six-month rule," which sets a time limit for the prosecution of criminal cases in district court (para 1).

Procedural History

• District Court, April 14, 2008: All charges against the Defendant were dismissed due to a violation of the "six-month rule" (para 1).
• Court of Appeals, October 2009: Affirmed the district court's ruling (para 1).

Parties' Submissions

• Plaintiff-Petitioner (State): Argued that a case is pending until the appellate process has been ultimately exhausted, contending that Savedra, not the six-month rule, controls the outcome of this case (para 3).
• Defendant-Respondent: Argued that Savedra applies only to cases that were pending in district court as of May 12, 2010, and since the district court had dismissed all criminal charges well before this date, his case was no longer "pending" as of that date, thus the six-month rule should control the disposition of his case (para 3).

Legal Issues

• Whether the Defendant's case was still "pending" at the time Savedra issued on May 12, 2010, such that the six-month rule no longer controls his case (para 3).

Disposition

• The Supreme Court of New Mexico reversed the Court of Appeals and remanded to the district court for reinstatement of the criminal charges against the Defendant (para 13).

Reasons

• Per RICHARD C. BOSSON, Justice (CHARLES W. DANIELS, Chief Justice, PATRICIO M. SERNA, Justice, PETRA JIMENEZ MAES, Justice, EDWARD L. CHÁVEZ, Justice concurring): The Court clarified that Savedra applies to all pending cases that were not yet final as of May 12, 2010, defining "final" as any case where "a judgment of conviction has been rendered, the availability of appeal exhausted, and the time for a petition for certiorari elapsed or a petition for certiorari finally denied" (paras 4-11). The Court addressed the confusion and conflicting interpretations among the Court of Appeals regarding the application of Savedra and the definition of "pending" (paras 4-7). It emphasized the policy concerns that motivated the decision in Savedra, particularly the intention to move away from the overly technical application of the six-month rule and towards a more substantive evaluation of speedy trial claims under the Sixth Amendment (paras 8-9). The Court also clarified that Article IV, Section 34 of the New Mexico State Constitution does not apply to rule changes implemented by the Court, in the absence of some affirmative act to the contrary (para 11).