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, a sixteen-year-old, pleaded guilty to several felony offenses, including aggravated burglary with a deadly weapon, conspiracy to commit aggravated burglary, unauthorized use of another's card, residential burglary, and auto burglary. Following a plea and disposition agreement, an amenability hearing was held to determine whether the Defendant would receive an adult sentence or juvenile sanctions. The district court found the Defendant not amenable to treatment as a juvenile and sentenced him as an adult to thirty-one years and six months, with seventeen years and six months suspended (paras 1, 3-6).

Procedural History

• State v. Rodriguez, A-1-CA-37324, mem. op. ¶¶ 1, 9 (N.M. Ct. App. Nov. 27, 2019) (nonprecedential): The Court of Appeals held that the Defendant waived his right to appeal the amenability determination under the plea and disposition agreement.

Parties' Submissions

• Defendant-Petitioner: Argued that he did not and could not waive his right to challenge the district court’s amenability determination. Contended that the amenability determination cannot be waived by the child, thus retaining the right to appeal such a determination (para 8).
• Plaintiff-Respondent: Argued that the Defendant did not specifically reserve the right to appeal the amenability hearing in the plea and disposition agreement, and therefore, the waiver of defenses and right to appeal in the agreement controls (para 8).

Legal Issues

• Whether a juvenile waives the right to appeal an amenability determination by entering into a plea and disposition agreement.

Disposition

• The Supreme Court of the State of New Mexico reversed the Court of Appeals' decision, holding that a juvenile’s guilty plea may neither waive the right to an amenability determination nor the right to appeal the outcome of such a determination. The case was remanded to the Court of Appeals to consider the merits of the Defendant’s challenges to the amenability determination (para 26).

Reasons

• VIGIL, Justice, with C. SHANNON BACON, Chief Justice, DAVID K. THOMSON, Justice, BRIANA H. ZAMORA, Justice, and T. GLENN ELLINGTON, Judge concurring, provided the opinion. The Court reasoned that the right to appeal is a matter of substantive law and reviewed de novo the entitlement to appeal the result of the amenability hearing. It was determined that the amenability determination is a nonwaivable condition precedent to invoking an adult sentence. The Court further explained that a challenge to an amenability determination presents a jurisdictional argument that may be raised on appeal notwithstanding the entry of a valid guilty plea and appellate waiver. The decision emphasized the legislative intent behind the Delinquency Act to treat children as such for as long as they can benefit from treatment and rehabilitation provided for in the Act. The Court concluded that allowing a waiver of the right to appeal an amenability determination would undermine the purpose of the amenability hearing and the factors detailed in Section 32A-2-20(C) of the Delinquency Act (paras 8-26).