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

• On November 16, 2015, the defendant was accused of squirting gasoline on her husband's face and igniting it, causing severe burns. Following the incident, the husband was treated for his injuries. Despite initially reporting the event as an intentional act, the husband later recanted, claiming it was an accident. The case went to trial, where various witnesses, including the husband and a case agent, testified. During the trial, jurors reported feeling intimidated by the husband's behavior, including a throat-slashing gesture towards a witness (paras 2-5).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court abused its discretion by denying a motion for a mistrial based on jury intimidation and prosecutorial misconduct. Also claimed ineffective assistance of counsel for not pursuing an evidentiary hearing, failing to file a written motion for mistrial, and not requesting video evidence of the alleged jury intimidation (paras 10-11, 26-27).
• Plaintiff-Appellee: Contended that the presumption of prejudice no longer exists under New Mexico jurisprudence, and as the moving party, the defendant bore the burden of demonstrating prejudice. Argued that the district court did not abuse its discretion in denying the motion for mistrial and that the defendant's claims of prosecutorial misconduct and ineffective assistance of counsel were unfounded (paras 12-13, 24).

Legal Issues

• Whether the district court abused its discretion in denying the defendant's motion for a mistrial based on jury intimidation and prosecutorial misconduct.
• Whether the defendant was denied effective assistance of counsel due to counsel's failure to pursue certain actions during the trial (paras 10-11, 26-27).

Disposition

• The Court of Appeals affirmed the district court's decision, denying the defendant's motion for a mistrial and rejecting claims of prosecutorial misconduct and ineffective assistance of counsel (para 33).

Reasons

• The Court of Appeals found that the district court did not abuse its discretion in denying the motion for a mistrial, as the defendant did not meet the burden of showing that extraneous material reached the jury and was relevant to the case. The court also held that the district court was not required to conduct a sua sponte voir dire of the jury based on the notes received, as there was no evidence of juror tampering or bias that would necessitate such an action. Regarding the claim of prosecutorial misconduct, the court declined to address the issue due to the defendant's failure to develop the argument sufficiently. Lastly, the court concluded that the defendant did not make a prima facie case of ineffective assistance of counsel on direct appeal, as the record did not support the claims made (paras 11-32).