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 charged with multiple offenses following an incident involving his ex-girlfriend, E. Ramirez, on May 22, 2012. The charges included residential burglary, unlawful taking of a motor vehicle, stalking, larceny, and escape or attempt to escape from a peace officer. The relationship between the Defendant and Ms. Ramirez, who had a child together, ended shortly before the incident. On the day in question, the Defendant attempted to enter Ms. Ramirez's mother's home, made threats, and eventually left with Ms. Ramirez's purse and vehicle. The Defendant was arrested on June 6, 2012, after being found hiding in his father's home (paras 2-5).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellee (State of New Mexico): Argued that the Defendant's motion to represent himself was untimely and that his requests for new counsel and subsequent delays were tactics to thwart the orderly administration of justice (paras 11-16).
• Defendant-Appellant (Ernest Bryan Barela): Requested to represent himself on the morning of the trial, claiming dissatisfaction with his appointed counsel's preparation. Additionally, the Defendant appealed the denial of his motion for self-representation and claimed ineffective assistance of counsel (paras 7-9, 11).

Legal Issues

• Whether the Defendant's right to self-representation was unjustly denied by the district court.
• Whether the Defendant received ineffective assistance of counsel, warranting a reversal of his convictions and a remand for a new trial (paras 11-21).

Disposition

• The Court of Appeals affirmed the district court's decision, denying the Defendant's motion for self-representation and rejecting the claim of ineffective assistance of counsel (para 22).

Reasons

• The Court, with an opinion by Judge Michael E. Vigil, concurred by Judges Henry M. Bohnhoff and Daniel J. Gallegos, held that the Defendant did not clearly and unequivocally assert his intention to represent himself in a timely manner, nor did he make a valid knowing, intelligent, and voluntary waiver of his right to counsel. The Court found that the Defendant's repeated requests for new counsel and the resulting delays were tactics to secure delay, rendering his motion for self-representation untimely. Regarding the claim of ineffective assistance of counsel, the Court determined that the Defendant failed to establish that his counsel's performance was deficient or that any alleged deficiency prejudiced his defense. The Court emphasized the preference for bringing ineffective assistance claims through habeas corpus proceedings rather than on direct appeal, noting the record's insufficiency to support the Defendant's claims (paras 12-21).