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

• On November 7, 2010, Defendant William Pagan-Rivera entered the apartment of Martha Colwell and her sons, Ramon and Antonio Lopez, and family friend Dwayne King. A confrontation ensued, during which Pagan-Rivera brandished a firearm, demanded "Give it to me. I need it all," and fired the gun. The altercation moved outside, where Pagan-Rivera fired additional shots, one of which fatally wounded Dwayne King. Pagan-Rivera fled the scene but was later apprehended by police. No crack cocaine was found on King or at the scene, and despite a search, the revolver used was not located. Pagan-Rivera claimed his injuries were from falling on a toy truck, a statement contradicted by evidence and witness testimony (paras 3-12).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that his right to a speedy trial was violated, the district court improperly admitted a hospital statement violating physician-patient privilege, improperly allowed the lead investigative agent to remain in the courtroom, erroneously denied a motion for mistrial, convictions were not supported by sufficient evidence, and cumulative errors warranted reversal (para 1).
• Plaintiff-Appellee: Contended that the appeal should be dismissed based on established precedent and rules of court, indicating that the issues presented had been previously decided or were answered by statute or rules of court (para 2).

Legal Issues

• Whether the defendant's right to a speedy trial was violated.
• Whether the district court violated physician-patient privilege by admitting a statement made by the defendant at the hospital.
• Whether the district court violated the rule requiring the exclusion of witnesses by allowing the lead investigative agent to remain in the courtroom.
• Whether the district court erroneously denied the defendant's motion for mistrial.
• Whether the defendant's convictions are supported by sufficient evidence.
• Whether the district court’s errors rise to reversible cumulative error (para 1).

Disposition

• The Supreme Court of New Mexico affirmed the defendant's convictions for first-degree felony murder, two counts of negligently caused child abuse, shooting from a motor vehicle, shooting at a dwelling or occupied building, and tampering with evidence (para 65).

Reasons

• The court found no violation of the defendant's right to a speedy trial, noting the delays were largely attributable to the defense and the defendant did not meaningfully assert his right. The court ruled statements made by the defendant at the hospital to officers, when no medical personnel were present, were not protected by physician-patient privilege. The presence of the lead investigative agent in the courtroom was deemed not to have prejudiced the defendant's case. The court found no abuse of discretion in denying the defendant's motion for mistrial and concluded that substantial evidence supported each of the defendant's convictions. The court also found no cumulative error warranting reversal of the convictions (paras 17-64).