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 removed from the Navajo Nation and subsequently prosecuted for DWI in San Juan County Magistrate Court, following an initial conviction under Navajo law for the same offense. The Defendant's removal and evidence collection, specifically blood alcohol content, were conducted by Officer Gonzales, who was acting as a cross-commissioned officer.

Procedural History

• State v. Charlie, 2014 WL 7187049, Nos. 34,487 & 34,488, order (N.M. Sup. Ct. Dec. 18, 2014) (non-precedential): The Supreme Court remanded the case to consider issues not decided in the initial opinion.

Parties' Submissions

• Defendant-Appellant: Argued that evidence obtained during his removal from the Navajo Nation should be suppressed due to improper extradition procedures and that the successive prosecution violates his right to equal protection, as it subjects him to multiple prosecutions based on his status as an Indian.
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether evidence obtained during the Defendant's removal from the Navajo Nation should be suppressed.
• Whether the successive prosecution of the Defendant by both the Navajo Nation and the San Juan County Magistrate Court violates his right to equal protection.

Disposition

• The court affirmed the Defendant’s guilty plea conviction.

Reasons

• LINDA M. VANZI, Judge (JONATHAN B. SUTIN, Judge, J. MILES HANISEE, Judge concurring): The court held that the Defendant's argument regarding the suppression of evidence was an extension of a jurisdiction claim previously addressed by the Supreme Court, which found that extradition protocols were not required in this case, thus not entitling the Defendant to suppression of evidence (paras 4-5). Regarding the equal protection claim, the court determined that the Defendant waived any right to raise an equal protection claim by entering into a plea agreement and failing to preserve this argument in lower courts or on appeal. The court also noted that the Defendant had reserved the right to appeal only on jurisdictional issues, thereby waiving all other defenses and objections. The court declined to review the merits of the Defendant's equal protection claim under the fundamental error doctrine, stating that there was no fundamental error necessitating reversal of the conviction since the Defendant had knowingly and voluntarily waived his right to appeal the constitutionality of his plea conviction (paras 6-10).