State v. Brown

CourtNew Mexico Court of Appeals
DecidedJune 25, 2026
StatusUnpublished

This text of State v. Brown (State v. Brown) 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. Brown, (N.M. Ct. App. 2026).

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 Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions.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-41969

STATE OF NEW MEXICO,

Plaintiff-Appellee,

v.

DAVID BROWN,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF CURRY COUNTY Fred Van Soelen, District Court Judge

Raúl Torrez, Attorney General Benjamin L. Lammons, Assistant Solicitor General Santa Fe, NM

for Appellee

Bennett J. Baur, Chief Public Defender Maria A. Pomorski, Assistant Appellate Defender Santa Fe, NM

for Appellant

MEMORANDUM OPINION

HENDERSON, Judge.

{1} Defendant David Brown appeals his conviction for trafficking methamphetamine by possession with intent to distribute, contrary to NMSA 1978, Section 30-31-20(A)(3) (2006). On appeal, Defendant argues that (1) the district court erred in admitting undisclosed photographs at trial; (2) expert testimony regarding the ultimate issue in this case constituted plain error; and (3) there is insufficient evidence that Defendant intended to distribute methamphetamine. For the reasons that follow, we affirm. BACKGROUND

{2} On January 25, 2023, three probation officers conducted a visit of Defendant’s motel room in Clovis, New Mexico, where Defendant was staying with his girlfriend. The probation officers observed a crystalized substance and syringe in an open black box along with beer cans and a pipe on the nightstand, and contacted the Clovis Police Department. A sergeant then came to the motel to investigate.

{3} Upon arriving at the room, the sergeant located a black box, which contained a needle, baggies, loose methamphetamine, and a crystalized rock that later tested positive for methamphetamine on the nightstand. The sergeant also observed a digital scale on the nightstand and “some glass meth pipes and a large bong” on a nearby dresser. Defendant and his girlfriend then agreed to a search of the room. The sergeant searched the girlfriend’s purse and found baggies with a substance that tested positive for black tar heroin, blue pills that tested positive for acetaminophen though testing could not rule out fentanyl, and Xanax pills. As a result, Defendant was charged with two counts of trafficking a controlled substance by possession with intent to distribute, contrary to Section 30-31-20, for the heroin and methamphetamine; and two counts of distribution of a controlled substance, contrary to NMSA 1978, Section 30-31-22 (2021), for the Xanax and fentanyl.

{4} At trial, the State began to ask one of the probation officers about four photographs she had taken while in the motel room. One of the photographs—the main photograph at issue and admitted as State’s Exhibit 2—showed a black box containing methamphetamine, a syringe, and baggies on the nightstand, but inaccurately showed marked baggies of Xanax and fentanyl on the nightstand as well, which had been placed there later by investigators. Defendant immediately asked to approach the bench, asserting that the State had not provided the photographs during discovery in this case. The State asserted that the photographs had been in discovery “for some time” and that the photographs were also mentioned in reports for Defendant’s separate probation violation case. Defendant again asserted that he was not provided the photographs—to include Exhibit 2, which inaccurately shows the Xanax and fentanyl baggies on the nightstand—in discovery, nor were Defendant’s probation reports provided in this case.

{5} The district court heard argument outside the presence of the jury about the admissibility of the photographs. Defendant argued that admission would be prejudicial because counsel was not able to advise Defendant on all of the evidence the State had against him and Defendant believed that the other drugs photographed on the nightstand had been moved from their original locations before the photographs were taken, such that defense counsel would have used the photographs in pretrial interviews and to impeach the State’s witnesses. The district court then questioned the parties about production of the photographs during discovery. The State conceded that it could not definitively state whether the photographs were produced during discovery; however, the State again asserted that black and white copies of the photographs were provided in Defendant’s separate probation violation case. {6} To address the potential discovery violation, the district court made color copies of the photographs and allowed Defendant to question the probation officer about them. After questioning the probation officer outside the presence of the jury, Defendant renewed his objection to admission of the photographs. The State admitted that the photographs were disclosed late. The district court found that while the photographs were not timely disclosed, the “only prejudice [counsel was] asserting is that you just didn’t have them beforehand to properly advise your client” and any prejudice to Defendant was insufficient to warrant their exclusion.

{7} The probation officer’s testimony regarding the photographs then resumed, and she testified that three of the photographs, including Exhibit 2—were taken when she first arrived to the room, showing the scene as it was before anything was moved during the investigation, and the fourth photograph was taken after the sergeant collected and placed items in the box for transport to the police department. The district court admitted the photographs, including Exhibit 2, over Defendant’s objections.

{8} The sergeant testified next and agreed that the first three photographs, including Exhibit 2, depicted the nightstand as it was when he arrived at Defendant’s room, with the methamphetamine, baggie of Xanax pills, baggie of fentanyl pills, a blowtorch, and a crushed can with methamphetamine residue visible. He also explained that the fourth photograph depicted the nightstand after he had searched the room and “collected everything.” On cross-examination, Defendant attempted to impeach the sergeant’s earlier direct testimony with his police report, which stated that the baggies containing fentanyl and Xanax were found in the girlfriend’s purse. The sergeant claimed that his testimony on direct examination, that these items were found on the nightstand, was correct and that any misrepresentation was in his police report.1

{9} Additionally, the sergeant was qualified as an expert in narcotics investigations and narcotics trafficking, and testified that the crystalized rock tested positive for methamphetamine and that the amount of methamphetamine found in Defendant’s motel room, “approximately ten grams,” was not that of a typical user. The sergeant testified that he has seen this amount in other trafficking cases and that based on his training and experience, “there was narcotics trafficking happening in that room,” because of “the amount of methamphetamine located along with the scale and the baggies located.” He then reiterated his opinion that, “I believe that there was indeed narcotics trafficking happening from that hotel room” based on the scale, labelled and prepackaged baggies, and amount of methamphetamine found.

{10} The State then had a forensic chemistry expert testify as to testing of the drugs found. At the close of the State’s case, Defendant moved for directed verdicts on all charges. The district court granted the motion with respect to Defendant’s heroin charge because the evidence showed the heroin was found in the girlfriend’s purse, but denied

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Cite This Page — Counsel Stack

Bluebook (online)
State v. Brown, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-brown-nmctapp-2026.