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, Crystal Ortiz, was indicted on five counts related to an incident where, while intoxicated, she drove her vehicle into her ex-boyfriend, Brandon Hughes, causing him severe leg injury, and then fled the scene. During her trial, Ortiz sought a jury instruction on duress, claiming Hughes' threatening behavior compelled her actions. However, she testified that hitting Hughes was accidental, leading the district court to deny the duress instruction based on her claim of accidental action (paras 3-6).

Procedural History

• State v. Ortiz, 2018-NMCA-018: The Court of Appeals reversed the district court's decision, holding that Ortiz was entitled to a duress instruction for the jury regarding two of the charges against her (para 9).

Parties' Submissions

• Plaintiff-Petitioner (State of New Mexico): Argued that the defendant's contention that she accidentally perpetrated the criminal acts precludes her from asserting duress as a defense to the crimes charged (para 11).
• Defendant-Respondent (Crystal Ortiz): Sought a jury instruction on duress, claiming her actions were compelled by the threatening behavior of Hughes. Ortiz argued that the circumstances, including previous alleged rape and aggressive behavior by Hughes on the night of the incident, justified consideration of duress (paras 5-6, 9).

Legal Issues

• Whether the defendant is entitled to a duress instruction for the jury when she claims that the criminal act was committed accidentally (para 11).

Disposition

• The Supreme Court of the State of New Mexico reversed the Court of Appeals' decision, holding that Ortiz was not entitled to a duress instruction for the crimes of great bodily injury by vehicle and aggravated battery. The case was remanded to the Court of Appeals to consider Ortiz’s double jeopardy arguments that were not previously addressed (para 27).

Reasons

• The Supreme Court, in an opinion by Chief Justice Judith K. Nakamura, with Justices Barbara J. Vigil, C. Shannon Bacon, David K. Thomson concurring, and Judge Mary L. Marlowe Sommer sitting by designation, provided several reasons for their decision:
  The Court clarified that a defendant seeking a duress instruction must admit to committing the criminal act but argue that the act was compelled by an imminent threat of serious harm. Since Ortiz testified that her actions were accidental, she could not meet this requirement (paras 12-15).
  The Court examined the evidence presented at trial, including Ortiz's testimony and the circumstances leading to the incident, concluding that Ortiz's claim of accidental action contradicted the requirement for a duress defense that the defendant admit to the criminal act (paras 19-25).
  The Court emphasized that duress presupposes intentional or volitional action in committing a crime, which was not compatible with Ortiz's defense that she accidentally struck Hughes (paras 25-26).