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 aggravated assault against a household member (deadly weapon), false imprisonment, and aggravated assault (deadly weapon). The State dismissed all but the last charge before the trial. The district court dismissed the remaining charge with prejudice due to the State's failure to bring the case to trial within the deadline set by LR2-308 NMRA, leading to the State's appeal (paras 1-3).

Procedural History

• Metropolitan Court, May 2, 2018: Found probable cause and granted pretrial preventive detention based on the Defendant's danger to the community (para 3).
• Second Judicial District Court, May 16, 2018: Defendant was indicted by a grand jury (para 4).
• Second Judicial District Court, January 30, 2019: Dismissed the case with prejudice for failing to commence trial within the deadline set by LR2-308 (para 12).

Parties' Submissions

• State: Argued that the district court erred by dismissing the case for lack of jurisdiction and that LR2-308 does not mandate dismissal with prejudice for failing to commence trial within the set deadline (para 2).
• Defendant: Filed a motion to exclude witness testimony due to the State's failure to make them available for interviews and later requested the case be dismissed as a sanction for not commencing trial by the LR2-308 deadline (paras 8, 10).

Legal Issues

• Whether the district court erred in dismissing the case with prejudice on the grounds of jurisdictional failure due to not commencing trial within the deadline set by LR2-308 NMRA (para 2).
• Whether LR2-308 mandates dismissal with prejudice if a trial does not commence within the set deadline (para 2).

Disposition

• The Court of Appeals reversed the district court's decision and remanded the case to determine, at its discretion, whether the State is responsible for the delay and, if so, what sanction is appropriate under LR2-308(H)(1) (para 27).

Reasons

• Per Yohalem, J. (Bogardus and Duffy, JJ., concurring): The Court found that the district court erred in concluding that LR2-308's deadlines are jurisdictional and that the rule mandates dismissal with prejudice for failing to commence trial within the deadline. The Court held that LR2-308 is not jurisdictional and does not require dismissal with prejudice, leaving the type of sanction for non-compliance to the district court's discretion. The Court emphasized that the district court must consider the circumstances and reasons for the failure to comply when deciding on an appropriate sanction (paras 15-26).