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 convicted of offenses and sentenced by the district court on June 23, 2021. Following an unsuccessful appeal where the convictions were affirmed, and after the New Mexico Supreme Court denied the Defendant's petition for writ of certiorari, the Defendant filed a motion to reduce sentence under Rule 5-801 NMRA within ninety days of the district court receiving the mandate from the appellate court affirming the judgment (paras 3-4).

Procedural History

• District Court, June 23, 2021: Defendant was convicted and sentenced (para 3).
• Court of Appeals, March 21, 2023: Affirmed the convictions on appeal (para 3).
• New Mexico Supreme Court, (N/A): Denied Defendant's petition for writ of certiorari, after which the mandate was issued on October 6, 2023 (para 3).

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred in ruling it lacked jurisdiction to consider his motion for sentence reduction, asserting that the motion was timely filed within ninety days after the district court received the appellate court's mandate affirming his conviction (para 4).
• Plaintiff-Appellee (State): Conceded that the district court's ruling of lacking jurisdiction was in error (para 4).

Legal Issues

• Whether the district court erred in ruling it lacked jurisdiction to consider the Defendant's motion for sentence reduction under Rule 5-801 NMRA because it was filed more than ninety days after the sentence was imposed, without considering the timing in relation to the receipt of the appellate court's mandate.

Disposition

• The Court of Appeals reversed the district court's denial of the Defendant's motion to reduce sentence and remanded the case for proceedings consistent with the opinion (para 6).

Reasons

• The panel, consisting of Chief Judge Jennifer L. Attrep, Judge Zachary A. Ives, and Judge Jane B. Yohalem, unanimously found that the district court erred in its jurisdictional ruling. The Court of Appeals determined that, according to Rule 5-801(A)'s plain language, a motion to reduce sentence can be filed within ninety days after the district court receives a mandate from an appellate court following the affirmance of the judgment on appeal. Since the Defendant's motion was filed within this timeframe, the district court indeed had jurisdiction to consider the motion. The appellate court's decision was based on the interpretation of Rule 5-801(A) and relevant case law regarding the timeliness and jurisdictional nature of such motions (paras 2-6).