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 sixteen offenses related to six burglaries and one attempted burglary in Taos, New Mexico, between March and December 2018. The crimes involved nonresidential burglary, larceny, criminal damage to property, breaking and entering, and attempted burglary. The Defendant appealed, challenging the convictions on double jeopardy grounds, arguing that the district court improperly increased his sentence based on uncharged crimes, and contending that a search warrant for cell site location records was unconstitutionally broad.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that convictions for breaking and entering, larceny, and criminal damage to property, in addition to burglary, violated double jeopardy. Contended the district court improperly increased his sentence based on uncharged and unproven crimes. Also argued that a search warrant for cell site location records was unconstitutionally broad, requiring reversal and remand for a new trial.
• Plaintiff-Appellee: The State presumably defended the convictions and the sentence imposed by the district court, although specific arguments are not detailed in the decision.

Legal Issues

• Whether the Defendant's convictions for breaking and entering, larceny, and criminal damage to property, in addition to burglary, violated his right to be free from double jeopardy.
• Whether the district court improperly increased the Defendant's sentence based on uncharged and unproven crimes.
• Whether a search warrant for cell site location records was unconstitutionally broad, necessitating reversal and remand for a new trial.

Disposition

• The Court vacated the Defendant's conviction for breaking and entering and two of his three convictions for criminal damage to property due to double jeopardy violations but affirmed the remaining convictions.
• The Court remanded the case to the district court to determine which of the two convictions (nonresidential burglary or breaking and entering) should be vacated and for resentencing.

Reasons

• The Court found that the Defendant’s conviction for breaking and entering and two of his three convictions for criminal damage to property violated his right to be free from double jeopardy and must be vacated (paras 28-32, 38-42).
  The Court disagreed with the Defendant's double jeopardy claims regarding his convictions for both burglary and larceny, finding the conduct underlying these convictions was not unitary (paras 33-36).
  The Court did not find fundamental error in the district court's consideration of uncharged crimes for sentencing purposes, noting recidivism as an appropriate consideration (paras 44-47).
  The Court concluded that even assuming an error occurred regarding the search warrant for cell site location records, the Defendant did not demonstrate that this constituted fundamental error requiring reversal of his conviction, given the overwhelming evidence against him (paras 48-49).