State v. Armstrong

CourtNew Mexico Court of Appeals
DecidedOctober 16, 2025
StatusUnpublished

This text of State v. Armstrong (State v. Armstrong) 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. Armstrong, (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 Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions.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-41629

STATE OF NEW MEXICO,

Plaintiff-Appellee,

v.

MARQUI NIKOLE ARMSTRONG a/k/a MARQUI ARMSTRONG,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF MCKINLEY COUNTY R. David Pederson, District Court Judge

Raúl Torrez, Attorney General Santa Fe, NM Walter Hart, Assistant Solicitor General Albuquerque, NM

for Appellee

Bennett J. Baur, Chief Public Defender Kimberly Chavez Cook, Appellate Defender Santa Fe, NM

for Appellant

MEMORANDUM OPINION

WRAY, Judge.

{1} A jury convicted Defendant of (1) possession of a controlled substance, (methamphetamine), contrary to NMSA 1978 Section 30-31-23(A), (E) (2021); and (2) trafficking a controlled substance (fentanyl), contrary to NMSA 1978 Section 30-31-20 (2006). Defendant makes three arguments on appeal. We conclude the following: (1) assuming that the investigating officer provided expert testimony, the foundation for the officer’s qualifications was sufficient under the circumstances to avoid plain error and permitting the testimony was not otherwise error; (2) fundamental error did not arise from the State’s reference in closing argument to the general intent jury instruction; and (3) the search warrant affidavit established probable cause to search Defendant’s residence. We therefore affirm.

DISCUSSION

{2} Because this is a memorandum opinion, we reserve our discussion of the factual background for that necessary to explain our analysis.

I. The Investigating Officer’s Trial Testimony

{3} Defendant’s first argument relates to whether the testimony of the investigating officer (the officer) was improper expert testimony. The parties do not dispute that this issue was not preserved and is therefore subject to plain error review. See State v. Contreras, 1995-NMSC-056, ¶ 23, 120 N.M. 486, 903 P.2d 228 (noting that appellate courts review unpreserved evidentiary objections for plain error). “Under the plain error rule, there must be (1) error, that is (2) plain, and (3) that affects substantial rights.” State v. Gwynne, 2018-NMCA-033, ¶ 27, 417 P.3d 1157 (internal quotation marks and citation omitted). Defendant maintains that the admission of the officer’s testimony was plainly erroneous, cumulatively affected substantial rights, and undermined the right to a fair trial. See State v. Stanley, 2001-NMSC-037, ¶ 43, 131 N.M. 368, 37 P.3d 85 (“Under the cumulative error doctrine, we consider whether the cumulative effect of the errors was so prejudicial that [the d]efendant was deprived of a fair trial.”).

{4} Whether there was error at all is the starting point for reversible, plain, and cumulative error analysis. See State v. Smith, 2016-NMSC-007, ¶ 46, 367 P.3d 420 (explaining reversible error); Gwynne, 2018-NMCA-033, ¶ 27 (noting that the first criteria for plain error is that “there must be . . . error”); State v. Samora, 2013-NMSC- 038, ¶ 28, 307 P.3d 328 (“Where there is no error to accumulate, there can be no cumulative error.” (alteration, internal quotation marks, and citation omitted)). Defendant’s assignments of error implicate the expert testimony requirements found in Rule 11-702 NMRA and whether the officer’s testimony (1) created an improper profile of drug traffickers, (2) was “unduly prejudicial under Rule 11-403 NMRA,” and (3) resulted in an inadmissible opinion about the ultimate issue that was for the jury to decide. We begin with Rule 11-702, explain how the profile and prejudice arguments are tied to the Rule 11-702 arguments, and then address the ultimate issue question.

A. The Requirements of Rule 11-702

{5} Rule 11-702 generally governs the admissibility of expert testimony. The rule permits a witness to “testify in the form of an opinion,” id., subject to three requirements: “(1) that the expert be qualified; (2) that the testimony be of assistance to the trier of fact; and (3) that the expert’s testimony be about scientific, technical, or other specialized knowledge with a reliable basis.” State v. Yepez, 2021-NMSC-010, ¶ 19, 483 P.3d 576 (internal quotation marks and citation omitted). It is the role of the district court “to ensure that the proffered expert evidence meets the foregoing requirements.” Id. Based on this rule, Defendant argues the following: the officer’s testimony was expert testimony; the officer was not properly tendered or accepted as an expert; the officer was not qualified to provide some of the testimony; and the testimony did not assist the trier of fact.

{6} We need not decide whether all of the officer’s testimony that Defendant challenges was expert testimony. Much of the officer’s testimony was opinion testimony that was based on the officer’s experience and training. And on appeal, the State does not contest that the officer’s testimony was expert testimony but instead argues that no plain error arose from the failure to formally tender and recognize the officer as an expert and that regardless, the officer was qualified to provide expert testimony. We therefore assume that some of the officer’s testimony was expert testimony and continue our analysis.

{7} To the extent that Defendant maintains that the absence of a formal tender and recognition of the officer as an expert was plain error, we disagree. A district court need not signal its “acceptance of a witness as an expert” by using “formal, talismanic words,” instead “a witness may testify as an expert as long as the circumstances are such that the parties are on notice of the court’s acceptance of that witness as an expert.” State v. Bullcoming, 2010-NMSC-007, ¶ 30, 147 N.M. 487, 226 P.3d 1, rev’d on other grounds, Bullcoming v. New Mexico, 564 U.S. 647, 652, 658 (2011). The Bullcoming defendant objected to the expert’s testimony but the district court did not rule on the issue, and as a result, the Court focused on whether the parties had notice that the district court had accepted the witness as an expert despite no formal acceptance. Bullcoming, 2010- NMSC-007, ¶ 30. In the present case, Defendant did not object and as a result, the district court did not indicate its position on the matter. Nevertheless, assuming that the absence of formal or informal tender and acceptance was error, it was not plain error because as we explain, the record reflects that the parties and the district court were “on notice” that the officer’s testimony was based in part on his specialized knowledge and training. See id.

{8} The State began the officer’s testimony by asking a series of questions about his experience and training with drug investigations. During direct testimony, the officer testified repeatedly based on his experience and training, and some of Defendant’s questions during cross-examination were also premised on the officer’s experience and training. Thus, the record demonstrates that the parties were on notice that the testimony was based on both the officer’s experience and training in drug investigations and his factual knowledge about the investigation. As a result, we discern no plain error in permitting the officer’s expert testimony without tender and acceptance. See Gwynne, 2018-NMCA-033, ¶ 27 (explaining that plain error applies when “an error . . .

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Related

State v. Sosa
2009 NMSC 056 (New Mexico Supreme Court, 2009)
State v. Williamson
2009 NMSC 39 (New Mexico Supreme Court, 2009)
State v. Bullcoming
2010 NMSC 007 (New Mexico Supreme Court, 2010)
State v. Haidle
2012 NMSC 33 (New Mexico Supreme Court, 2012)
State v. Arrendondo
2012 NMSC 013 (New Mexico Supreme Court, 2012)
State v. Vest
2011 NMCA 37 (New Mexico Court of Appeals, 2011)
State v. Ashley
1997 NMSC 049 (New Mexico Supreme Court, 1997)
State v. Becerra
817 P.2d 1246 (New Mexico Court of Appeals, 1991)
State v. Trudelle
162 P.3d 173 (New Mexico Court of Appeals, 2007)
State v. Williamson
212 P.3d 376 (New Mexico Supreme Court, 2009)
State v. Stanley
2001 NMSC 037 (New Mexico Supreme Court, 2001)
State v. Contreras
903 P.2d 228 (New Mexico Supreme Court, 1995)
State v. Gee
2004 NMCA 042 (New Mexico Court of Appeals, 2004)
Lytle v. Jordan
2001 NMSC 016 (New Mexico Supreme Court, 2001)
State v. Trujillo
2002 NMSC 005 (New Mexico Supreme Court, 2002)
State v. Rael-Gallegos
2013 NMCA 92 (New Mexico Court of Appeals, 2013)
State v. Smith
2016 NMSC 007 (New Mexico Supreme Court, 2016)
State v. Gwynne
417 P.3d 1157 (New Mexico Court of Appeals, 2018)
Commonwealth v. Morris
974 N.E.2d 1152 (Massachusetts Appeals Court, 2012)
State v. Trudelle
2007 NMCA 066 (New Mexico Court of Appeals, 2007)

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