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Facts

  • On November 27, 2008, Christine Stump, a paramedic, responded to an emergency involving a patient's suicide attempt. During the intervention, Albuquerque Police Department (APD) officers handcuffed the patient, who was not cooperating. An incident occurred where APD Officer Regina Sanchez pushed the patient's head and neck down, which Stump perceived as endangering the patient. Stump intervened, leading to her arrest for battery on a peace officer. The parties later agreed to use the City of Albuquerque’s Alternative Dispute Resolution Program, resulting in the dismissal of charges against Stump and an agreement on expungement, contingent on no civil action from Stump (paras 4-9).

Procedural History

  • Stump v. Albuquerque Police Department, D-202-CV-2010-08145, Final Post-Remand Order, June 23, 2015: The district court denied Stump’s request to expunge her arrest records, concluding that the circumstances did not justify expungement and emphasizing New Mexico's policy favoring transparency (para 10).

Parties' Submissions

  • Appellant (Stump): Argued that the district court has the inherent authority to expunge her criminal records and that it abused its discretion by denying her request. Stump highlighted the extraordinary circumstances of her arrest, stemming from a misunderstanding, and the lack of opposition to her expungement request in district court (para 12).
  • Respondents (APD and others): [Not applicable or not found]

Legal Issues

  • Whether the district court had the inherent authority to compel expungement of Stump’s criminal record.
  • If so, whether the district court abused its discretion in concluding that the circumstances in this case were not extraordinary and did not warrant expungement (para 11).

Disposition

  • The Supreme Court of New Mexico affirmed the district court's decision to deny Stump's request for expungement of her arrest records (para 17).

Reasons

  • The Supreme Court, with Justices Charles W. Daniels, Petra Jimenez Maes, Edward L. Chávez, Barbara J. Vigil, and Judith K. Nakamura, unanimously concluded that the district court did not abuse its discretion in denying Stump’s expungement request. The Court found that the circumstances of Stump's arrest, despite being based on a misunderstanding, did not reach the level of egregiousness necessary to justify expungement. The Court distinguished this case from Concha v. Sanchez, where expungement was ordered due to an unprecedented abuse of power, noting that Stump's situation did not involve constitutional or unlawful charges but rather a misunderstanding resolved through mediation. The Court emphasized that it is not bound by agreements between parties or government concessions regarding expungement (paras 12-16).
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