State v. Carbajal

CourtNew Mexico Court of Appeals
DecidedNovember 19, 2025
StatusUnpublished

This text of State v. Carbajal (State v. Carbajal) 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. Carbajal, (N.M. Ct. App. 2025).

Opinion

The slip opinion is the first version of an opinion released by the Clerk of the Court of Appeals. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Clerk of the Court for compliance with Rule 23-112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion. 1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number: __________

3 Filing Date: November 19, 2025

4 No. A-1-CA-41987

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee,

7 v.

8 VINCENT MARIO CARBAJAL,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF OTERO COUNTY 11 Stephen Ochoa, District Court Judge

12 Raúl Torrez, Attorney General 13 Santa Fe, NM 14 Christa Street, Assistant Solicitor General 15 Albuquerque, NM

16 for Appellee

17 Bennett J. Baur, Chief Public Defender 18 Nina Lalevic, Assistant Appellate Defender 19 Santa Fe, NM

20 for Appellant 1 OPINION

2 YOHALEM, Judge.

3 {1} Defendant Vincent Mario Carbajal appeals his conviction of one count of

4 possession of a stolen motor vehicle, contrary to NMSA 1978, Section 30-16D-4(A)

5 (2009, amended 2025), 1 asserting two claims of error. First, Defendant claims that

6 his conviction must be vacated because the general/specific rule of statutory

7 construction requires a prosecutor to charge the unlawful taking of a motor vehicle,

8 NMSA 1978, § 30-16D-1(A) (2009, amended 2025)—the statute Defendant alleges

9 is more specific—rather than possession of a stolen motor vehicle, Section 30-16D-

10 4(A)—the statute Defendant alleges is more general—when there is evidence

11 supporting the violation of both statutes. Defendant also claims that the in-court

12 identification procedure employed to allow a witness to identify Defendant at trial

13 was unduly suggestive and violated his constitutional right to due process. We

14 affirm.

15 BACKGROUND

16 {2} On September 4, 2021, Phillip Herrera (Victim) drove to his farm to perform

17 maintenance checks during a rainstorm. Victim parked on the side of the highway

1 The offense occurred in 2021. We therefore rely on the 2021 version of the statute, which has a 2009 amendment date. All references to 30-16D-1 and 30-16D-4 refer to the 2009 amendment. 1 and left his keys, wallet, and phone inside his truck. When Victim next checked, his

2 truck was gone. Victim drove home on a farm vehicle and called the police.

3 {3} On September 10, 2021, a deputy from the Otero County Sheriff’s Office saw

4 Victim’s truck and conducted a traffic stop. Defendant was driving. Defendant

5 admitted to the deputy that he was not the owner of the truck and had been driving

6 it for “maybe five days, five seven days.” Defendant also told the deputy, “This may

7 sound weird to you . . . [the day I took the truck] I kept seeing a white truck pull over

8 . . . it may sound crazy but, I feel like [the truck] found me.” Defendant was arrested

9 and charged with possession of a stolen vehicle.

10 {4} At trial, the State called the deputy to testify. The State asked the deputy to

11 identify Defendant as the person who was driving Victim’s truck. “All right, so

12 you’ve said the name Vincent Carbajal—is that person here with us in the courtroom

13 today?” The trial was conducted with COVID-19 protocols that required everyone

14 in the courtroom to wear a mask, and the deputy stated that he could not answer the

15 State’s question with Defendant wearing a mask. The State requested that the court

16 require Defendant, seated at the defense table, to briefly remove his mask. “Your

17 Honor, is it permissible that the mask be removed momentarily?” [Id.] Defense

18 counsel objected, arguing that this would be unduly suggestive to the deputy that

19 Defendant was in fact the individual driving Victim’s truck. The court overruled the

20 objection and instructed Defendant, “Mr. Carbajal, will you pull your mask down 1 for a few short seconds.” The deputy identified Defendant as the man who had been

2 driving Victim’s truck.

3 {5} At the close of the State’s evidence, Defendant moved for a directed verdict,

4 arguing that the State incorrectly charged him with possession of a stolen motor

5 vehicle when it had sufficient evidence to prove that he had committed the offense

6 of unlawful taking of a motor vehicle. The district court denied Defendant’s motion.

7 {6} During closing argument, defense counsel conceded that Defendant was in

8 possession of Victim’s stolen truck, stating, “No doubt, of course, [the deputy] saw

9 him driving.” The defense theory for acquittal was that Defendant should be

10 acquitted even though he was driving the stolen truck because he was in the middle

11 of a mental health crisis, and therefore, he lacked criminal intent. Defendant was

12 convicted of possession of a stolen vehicle and timely appealed.

13 DISCUSSION

14 {7} Defendant argues on appeal that the general/specific rule of statutory

15 construction should be applied to the crimes of unlawful taking of a motor vehicle,

16 in violation of Section 30-16D-1, and possession of a stolen vehicle, in violation of

17 Section 30-16D-4. According to Defendant, when there is evidence that both crimes

18 were committed, the State must charge the allegedly more specific crime of unlawful

19 taking, and cannot choose to charge the allegedly general crime of possession of a

20 stolen vehicle. 1 {8} Although Defendant relied primarily on double jeopardy authority in arguing

2 his motion for directed verdict, rather than on precedent addressing the

3 general/specific rule of statutory construction, the State has not claimed lack of

4 preservation on appeal. Because both the State and the district court apparently

5 understood Defendant’s argument to question the State’s discretion to choose to

6 prosecute unlawful possession, rather than unlawful taking, and because of the

7 overlap between double jeopardy principles and the general/specific rule, we

8 exercise our discretion to address the merits of this issue on appeal. See Quintana v.

9 Baca, 1999-NMCA-017, ¶ 12, 126 N.M. 679, 974 P.2d 173 (exercising discretion to

10 dispose of a dispute on its merits where the district court was advised of the general

11 theory discussed on appeal); see also Jaramillo v. Gonzales, 2002-NMCA-072, ¶ 10,

12 132 N.M. 459, 50 P.3d 554 (reviewing an issue that was arguably not preserved

13 when the general theory was discussed in the district court).

14 {9} Additionally, Defendant claims that his right to due process under both the

15 United States and New Mexico Constitutions was violated when the court singled

16 him out to remove his mask so that the witness could identify him in front of the

17 jury. We address each argument in turn. 1 I. The General/Specific Rule of Statutory Interpretation Does Not Limit 2 Prosecutorial Discretion to Choose Between Prosecuting Possession or 3 Taking of a Motor Vehicle

4 {10} “The general/specific statute rule is a tool in statutory construction.” State v.

5 Santillanes, 2001-NMSC-018, ¶ 7, 130 N.M. 464, 27 P.3d 456. “The goal of the

6 general/specific statute rule in the context of criminal law is to determine whether

7 the Legislature intends to punish particular criminal conduct under a specific statute

8 instead of a general statute.” Id. ¶ 11. “The general/specific statute rule requires in

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State v. Carbajal, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-carbajal-nmctapp-2025.