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 and his girlfriend visited her family in Shiprock, New Mexico. An argument ensued during dinner, leading to a confrontation with the girlfriend's relatives. The Defendant was threatened with a shotgun by the girlfriend's sister and was told to leave. While driving away from the incident, the Defendant was stopped by police and subsequently arrested for driving while intoxicated (DWI) and having an open container in the vehicle. The Defendant's breath alcohol test showed a blood alcohol level of .08.

Procedural History

• Magistrate Court: Convicted of DWI (first offense) and open container.
• District Court of San Juan County: On appeal, granted a directed verdict on the open container charge but convicted of DWI.

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by not instructing the jury on the defense of duress and by admitting the Intoxilyzer certification without allowing confrontation of the person who certified the machine.
• Plaintiff-Appellee: Contended that the district court's decisions regarding the jury instruction on duress and the admission of the Intoxilyzer certification were correct and should be affirmed.

Legal Issues

• Whether the district court erred in refusing to instruct the jury on the defense of duress.
• Whether the district court erred in admitting the Intoxilyzer certification into evidence.

Disposition

• The Court of Appeals affirmed the judgment of the district court, rejecting the Defendant's arguments regarding the jury instruction on duress and the admission of the Intoxilyzer certification.

Reasons

• Per JAMES J. WECHSLER, Judge (M. MONICA ZAMORA, Judge, J. MILES HANISEE, Judge concurring):
  The Court found that the district court did not err in refusing to instruct the jury on the defense of duress because the Defendant did not meet the narrow criteria required for such a defense in DWI cases. Specifically, the Defendant failed to demonstrate that he had no reasonable legal alternative to driving while intoxicated. The Court also held that the district court did not err in admitting the Intoxilyzer certification into evidence, citing precedent that the scientific reliability of the breathalyzer is a foundational issue not subject to the Confrontation Clause. The Court's decision was based on the lack of evidence that the Defendant was in imminent danger after leaving the house and the established scientific reliability of the Intoxilyzer machine.