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 State of New Mexico appealed the district court's decision to dismiss a case without prejudice against Defendant Raymond Willie. The dismissal followed the district court's exclusion of all exhibits submitted by the State at a dangerousness hearing, based on the State's failure to consult the Defendant about the exhibits' admissibility forty-eight hours prior to the hearing, as mandated by the New Mexico Supreme Court COVID-19 Protocols.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellant (State of New Mexico): Argued that the district court erroneously excluded all exhibits submitted at the Defendant's dangerousness hearing as a sanction for not seeking the Defendant's position on the exhibits forty-eight hours prior to the hearing, as required by the New Mexico Supreme Court COVID-19 Protocols.
• Defendant-Appellee (Raymond Willie): Contended that the State failed to preserve the issue for review by not properly invoking a ruling or decision by the district court on the procedural abnormalities and the exclusion of the exhibits as a sanction.

Legal Issues

• Whether the district court abused its discretion by excluding all of the State's exhibits at the Defendant's dangerousness hearing as a sanction for failing to consult the Defendant about the exhibits' admissibility forty-eight hours prior to the hearing.
• Whether the State failed to preserve the issue for appellate review.

Disposition

• The case was remanded to the district court for further proceedings consistent with the opinion of the Court of Appeals.

Reasons

• Per Hanisee, C.J., with Bogardus and Yohalem, JJ., concurring:
  The Court of Appeals concluded that the district court abused its discretion by excluding the State's exhibits without conducting the proper inquiry under the Harper/Le Mier framework, which requires consideration of the culpability of the offending party, the prejudice to the adversely affected party, and the availability of lesser sanctions. The district court did not demonstrate consideration of these factors on the record before excluding the State's exhibits as a sanction (paras 4-5).
  The Court of Appeals disagreed with the Defendant's argument that the State failed to preserve the issue for review. The Court found that the State's actions at the hearing were sufficient to invoke a ruling on the admissibility of the documents and the propriety of exclusion as a sanction, thus preserving the issue for appellate review (para 6).