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 case involves the application of a new constitutional amendment in New Mexico that allows courts to deny pretrial release to felony defendants if clear and convincing evidence shows that no release conditions would reasonably protect the safety of any other person or the community. Two specific cases, State v. Salas and State v. Harper, were brought before the Supreme Court of New Mexico to provide guidance on the nature of evidence required in pretrial detention hearings under this amendment. Salas was charged with forty-seven armed robberies, and Harper was charged with attempted murder among other charges. Both were initially denied detention by the district court, which set high cash bonds instead (paras 6-8, 14-15).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Petitioner (Second Judicial District Attorney Raúl Torrez): Requested the Supreme Court to order new detention hearings for Salas and Harper, arguing for clarification on the evidentiary standards required for pretrial detention hearings under the 2016 constitutional amendment (paras 4, 25).
• Respondent (District Judge Stan Whitaker): Argued that due process may require live witness testimony at pretrial detention hearings and that in the cases of Salas and Harper, he did not abuse his discretion by requiring live witnesses (para 26).
• Real Parties in Interest (Paul Salas and Mauralon Harper): Supported the respondent's discretion to require live witnesses when the exhibits and proffers were deemed insufficient to meet the State’s burden of proof (para 27).
• Attorney General: Urged the Court to follow federal detention hearing precedents, allowing reliance on proffers and documents alone without violating due process rights but recognizing the court's discretion to require live witnesses when necessary for credibility or authenticity (para 28).

Legal Issues

• Whether the United States Constitution or the New Mexico Constitution requires live witness testimony at pretrial detention hearings (para 110).
• Whether judges can consider all reasonably reliable information, without regard to the formal rules of evidence, in determining whether any pretrial release conditions will reasonably protect the safety of any other person or the community (para 110).

Disposition

• The Supreme Court of New Mexico granted the State’s petition for writ of superintending control and remanded the cases of Salas and Harper to the district court for new hearings in conformity with the principles outlined in the Court's ruling (para 109).

Reasons

• The Court held that neither the United States Constitution nor the New Mexico Constitution categorically requires live witness testimony at pretrial detention hearings. It emphasized that judges may consider all reasonably reliable information, without regard to the formal rules of evidence, when determining whether any pretrial release conditions will reasonably protect the safety of any other person or the community. This decision was based on the interpretation of the new constitutional amendment, the procedural rules established by the Court, and a review of federal and state precedents on pretrial detention hearings. The Court also addressed the improper use of high cash bonds as a means to detain defendants who are otherwise eligible for pretrial release, clarifying that if a defendant is found too dangerous to release, a detention order should be entered instead of setting a high cash bond (paras 83-110).