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 by Officer Schake, a cross-commissioned officer, and subsequently charged with several crimes including DWI, open container of alcohol in a motor vehicle, no insurance, and failure to maintain a lane. The Defendant argued that evidence obtained during his removal should be suppressed and contended there was insufficient evidence to prove the crimes occurred outside the Navajo Nation.

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 Dec. 18, 2014) (non-precedential): The Supreme Court remanded the case to consider issues not decided in the initial opinion.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 (1) evidence obtained during his removal from the Navajo Nation should be suppressed because Officer Schake exceeded his authority by not following proper extradition procedures, and (2) there was insufficient evidence to prove that the Defendant drove outside the Navajo Nation.
• Plaintiff-Appellee: Contended that the Defendant's removal did not require extradition procedures as he was never released into another jurisdiction's custody. Also argued that there was sufficient evidence to support the jury's finding that the Defendant committed the charged crimes outside the Navajo Nation.

Legal Issues

• Whether evidence obtained during the Defendant's removal from the Navajo Nation should be suppressed.
• Whether there was sufficient evidence to support the jury’s finding that the Defendant committed the crimes outside the Navajo Nation.

Disposition

• The Court of Appeals affirmed the Defendant's convictions.

Reasons

• Per LINDA M. VANZI, J. (JONATHAN B. SUTIN, J., and J. MILES HANISEE, J., concurring):
  The Court found that the Defendant's argument for suppression of evidence was essentially a jurisdictional claim already addressed by the Supreme Court. Since the Defendant was not released into another jurisdiction's custody, extradition protocols were deemed unnecessary, and Officer Schake was acting within his authority as an enforcer of Navajo law (para 5). Regarding the sufficiency of the evidence, the Court highlighted that circumstantial evidence and corroborating testimony established that the crimes occurred in New Mexico, off the Navajo Reservation. Testimonies from a witness and Officer Schake, along with the Defendant's admissions and a forensic toxicologist's report, provided sufficient evidence to support the jury's findings (paras 6-12).