State v. Arias

CourtNew Mexico Court of Appeals
DecidedApril 21, 2025
StatusUnpublished

This text of State v. Arias (State v. Arias) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Arias, (N.M. Ct. App. 2025).

Opinion

This decision of the New Mexico Court of Appeals was not selected for publication in the New Mexico Appellate Reports. Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions. Electronic decisions may contain computer- generated errors or other deviations from the official version filed by the Court of Appeals.

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

No. A-1-CA-41156

STATE OF NEW MEXICO

Plaintiff-Appellee,

v.

RAFAEL ARIAS,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY Douglas R. Driggers, District Court Judge

Raúl Torrez, Attorney General Santa Fe, NM Peter James O’Connor, Assistant Solicitor General Albuquerque, NM

for Appellee

Bennett J. Baur, Chief Public Defender Brian Parrish, Assistant Appellate Defender Santa Fe, NM

for Appellant

MEMORANDUM OPINION

HANISEE, Judge.

{1} Defendant Rafael Arias was convicted by a jury of the following sex crimes perpetrated against his daughter (Child): two counts of first-degree criminal sexual penetration of a minor, contrary to NMSA 1978, Section 30-9-11(D)(1) (2009); two counts of second-degree criminal sexual contact of a minor, contrary to NMSA 1978, Section 30-9-13(B)(1) (2003); and two counts of third-degree criminal sexual contact of a minor, contrary to Section 30-9-13(C)(1). Defendant appeals his convictions, advancing three primary arguments. First, Defendant asserts that the district court erred in denying his motion for a new trial, filed after Child recanted her trial testimony at his sentencing hearing. Second, Defendant argues the district court committed reversible error when it allowed the State’s expert witness on child sexual abuse and trauma to comment on Child’s credibility. Lastly, Defendant argues that there is insufficient evidence supporting each conviction because the State failed to establish that the alleged crimes occurred within the time period identified in the indictment. We affirm.

DISCUSSION

I. Defendant’s Motion for a New Trial

{2} At trial, only three witnesses testified for the State: the investigating officer, Child, and an expert on child sexual assault and trauma. Child was the only witness who provided any factual testimony supporting the accusations against Defendant. The State introduced no other evidence of either a direct or circumstantial nature connecting Defendant to the charged offenses. At trial, Child testified extensively about the various assaults she suffered at the hands of Defendant.

{3} Despite what Child told jurors, she recanted her trial testimony at Defendant’s sentencing hearing. At sentencing, Defendant called Child, over the State’s objection, to testify for reasons not readily apparent at the outset of the hearing. Child willingly took the witness stand, and defense counsel immediately asked Child if she remembered testifying at trial, to which she responded, “Yes.” Defense counsel then asked whether Child was “truthful at trial” when Child said Defendant sexually abused her. The district court immediately halted the hearing to give Child the opportunity to seek counsel.

{4} Defendant thereafter filed a motion for a new trial, asserting that Child’s recantation testimony at sentencing constituted newly discovered evidence justifying such relief. At the following hearing on Defendant’s motion, Defendant again called Child to testify. The district court began the hearing by questioning Child, during which Child confirmed that she had previously attempted to recant her trial testimony and that she understood such an act exposed her to a charge of perjury. The district court then ensured Child understood her rights against self-incrimination and that she had been fully advised by an attorney on the matter. After the district court’s questions, the defense attorney asked Child about each alleged offense discussed by Child at trial, and whether Child had “lied” during her testimony.

{5} Regarding each alleged offense, Child stated that her trial testimony was false and that Defendant never assaulted her. The defense attorney finished his questions by asking Child whether Defendant had “ever sexually penetrated [her] with his penis— ever—in [her] lifetime.” Child responded, “No.” Defense counsel then asked whether Defendant had ever touched her “in a sexually abusive way—ever—in [her] lifetime.” Child again responded, “No.” Child thereafter repeated her assertion that she lied at trial. {6} After cross-examination by the State, which led to no further changes to Child’s recantation, the district court reserved ruling on Defendant’s motion for a new trial and permitted the parties fifteen days to submit additional filings. The State filed two supplemental response briefs in which it described three jailhouse phone calls between Defendant and others that, according to the State, indicated “persons engaged in improper influence of [Child] to cause her to change her testimony.” Another hearing was then held during which the State attempted to admit the phone calls into evidence. The district court interrupted the State during its introduction of these phone calls, and the following exchange occurred:

District court: [Defense counsel], do you have any objection to the State’s proffer made in response[s] that there were three phone calls made and one of them said w is contained in the State’s [supplemental] response [to Defendant’s motion]

....

Defense counsel: You’re asking me to . . . give that credence?

District court: No. I’m asking if you have any reason to believe that the phone calls were n made or they were not stated as represented by the State in their supplementals.

Defense counsel: No, Judge. I don’t have any reason to believe that they weren’t made or tha that’s not, in essence, what was said.

District court: Alright. Any additional argument, [prosecution]?

Without much further discussion, the district court took judicial notice of the phone calls as they were represented by the State in its supplemental briefing, did not admit them into evidence or verify their content, and denied Defendant’s motion for a new trial.

{7} In its order, the district court stated three general bases for its decision. First, it stated, without clear explanation, that the jury verdict was “not based on uncorroborated testimony.” Second, the district court found, based on the State’s characterization of the phone calls between Defendant and others—and Defendant’s associated apparent concession to the nature and occurrence of such calls—that Child’s recantation “occurred under suspicious circumstances and undue influence.” It concluded that there “was some plan afoot” to invalidate the jury verdict. And third, the district court found that, regardless of the recantation’s credibility, it did not warrant a new trial. On this point, the district court specifically found: (1) that the recantation was not “newly discovered” evidence; (2) Child was subjected to vigorous cross-examination; and (3) Child’s recantation “merely reflects potential impeachment material.” Defendant appeals.

{8} The grant or denial of a motion for a new trial lies within the sound discretion of the district court. State v. Jackson, 2018-NMCA-066, ¶ 32, 429 P.3d 674; State v. Sena, 1987-NMSC-038, ¶ 6, 105 N.M. 686, 736 P.2d 491. “An abuse of discretion occurs when the ruling is clearly against the logic and effect of the facts and circumstances of the case. We cannot say the trial court abused its discretion by its ruling unless we can characterize [the ruling] as clearly untenable or not justified by reason.” State v. Rojo, 1999-NMSC-001, ¶ 41, 126 N.M.

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Bluebook (online)
State v. Arias, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-arias-nmctapp-2025.