State v. Cerda

CourtNew Mexico Court of Appeals
DecidedJuly 25, 2022
StatusUnpublished

This text of State v. Cerda (State v. Cerda) 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. Cerda, (N.M. Ct. App. 2022).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk 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: July 25, 2022

4 No. A-1-CA-38464

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee,

7 v.

8 JAIME CERDA,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF OTERO COUNTY 11 Angie K. Schneider, District Judge

12 Hector H. Balderas, Attorney General 13 Santa Fe, NM 14 Walter Hart, Assistant Attorney General 15 Albuquerque, NM

16 for Appellee

17 Bennett J. Baur, Chief Public Defender 18 William O’Connell, Assistant Appellate Defender 19 Santa Fe, NM

20 for Appellant 1 OPINION

2 YOHALEM, Judge.

3 {1} Defendant Jaime Cerda appeals from the district court’s refusal to apply

4 presentence confinement credit to the second of his two consecutive sentences based

5 on convictions for related offenses when he had already been given credit for that

6 time toward his first sentence. Defendant relies on this Court’s decision in State v.

7 Ramzy, 1982-NMCA-113, 98 N.M. 436, 649 P.2d 504, to claim that presentence

8 confinement time can be credited to each of two consecutive sentences for related

9 offenses if the sentences are imposed in separate proceedings, at different times. We

10 agree with the district court that Defendant is not entitled to the same presentence

11 confinement credit against both sentences: presentence confinement credit is

12 imposed once against consecutive sentences in the aggregate, whether the sentencing

13 occurs in separate proceedings or in a single proceeding. We decline the State’s

14 invitation to overrule Ramzy and affirm the district court’s sentencing decision.

15 BACKGROUND

16 {2} Two criminal cases were brought against Defendant, both relating to events

17 that occurred on January 11, 2018. That day, Defendant fled from law enforcement

18 officers who were attempting a traffic stop and, while doing so, was seen throwing

19 plastic baggies out of his vehicle’s window. The bags were later recovered and

20 determined to contain methamphetamine. A short time later, the police found

21 Defendant hiding in a home and took him into custody. Two weeks later, on January 1 25, 2018, the State filed a complaint charging Defendant with aggravated fleeing a

2 law enforcement officer, possession of methamphetamine and marijuana, two counts

3 of tampering with evidence, resisting arrest, and possession of drug paraphernalia.

4 The parties refer to this as “Case Two.”1

5 {3} About a month after the events that led to Defendant’s arrest, the State learned

6 that Defendant had also been in possession of a firearm on January 11, 2018, and

7 had concealed that firearm before his arrest by dumping it over a wall onto a property

8 adjoining the house where he had been arrested. Following this new discovery, the

9 State initiated another criminal action on April 26, 2018, which the parties refer to

10 as “Case Three,” charging Defendant with one count of possession of a firearm by a

11 felon.

12 {4} Defendant was convicted at trial in Case Two and sentenced on November 16,

13 2018. At the time of his sentencing in Case Two, Defendant had been in custody

14 continuously since January 11, 2018. The district court imposed a prison term for

15 Case Two and subtracted presentence confinement credit of 310 days from that

16 sentence.

17 {5} This case, Case Three, was still pending at the time of Defendant’s sentencing

18 in Case Two. Two hundred and twenty-five days of the 310 days presentence

The parties’ briefing also refers to a “Case One,” which is not relevant to 1

Defendant’s sentencing claims on appeal. We will avoid further mention of “Case One” so as to minimize unnecessary confusion.

2 1 confinement credited to Defendant were served while Case Three was also pending

2 (from April 26, 2018, when Case Three was initiated, until November 16, 2018,

3 when Defendant was sentenced on Case Two, equals 225 days). Defendant later

4 pleaded guilty in Case Three and was sentenced to a prison term, ordered to run

5 consecutively to his prison term in Case Two. Defendant requested presentence

6 confinement credit for the 225 days he was confined while Case Three was pending,

7 even though those days had already been credited against his Case Two sentence.

8 The district court declined to do so, agreeing with the State that Defendant had

9 already been credited that time against a consecutive sentence in a related case and

10 was not entitled to double credit. This appeal followed.

11 DISCUSSION

12 {6} Defendant renews his argument on appeal that he is entitled, as a matter of

13 law, to what is effectively double credit for his presentence confinement: to have the

14 225 days he was confined before sentencing on both charges credited against each

15 consecutive sentence imposed by the district court, reducing the time he must serve

16 in prison for the two cases by a total of 450 days.

17 {7} Defendant relies on what he claims is the plain language of NMSA 1978,

18 Section 31-20-12 (1977). That section provides as follows:

19 A person held in official confinement on suspicion or charges of 20 the commission of a felony shall, upon conviction of that or a lesser 21 included offense, be given credit for the period spent in presentence 22 confinement against any sentence finally imposed for that offense.

3 1 {8} Defendant claims that this Court in Ramzy adopted his reading of Section 31-

2 20-12. Defendant relies on Ramzy’s holding that “the decisive factor in allowing

3 credit for presentence confinement in a case is whether the confinement was actually

4 related to the charges of that particular case. It is not necessary that the confinement

5 be related exclusively to the charges in question.” 1982-NMCA-113, ¶ 8. In

6 response, the State points to several subsequent cases, which it claims distinguish

7 Ramzy and argues that Ramzy ought to be overturned.

8 {9} We do not agree that Ramzy is applicable to this case or that the resolution of

9 this case requires us to overturn Ramzy. Ramzy does not address the central question

10 at issue in this case: when it is not disputed that a defendant’s presentence

11 confinement is occasioned by multiple related cases, is the defendant entitled to

12 credit against each consecutive sentence in those related cases simply because he

13 happens to be sentenced in separate proceedings?

14 {10} Ramzy addresses a period of confinement where the defendant was

15 incarcerated to serve a post-conviction sentence that had been imposed prior to his

16 commission of a new offense and at the same time, was incarcerated to await trial

17 and sentencing on a new offense. The defendant in Ramzy had been found guilty in

18 his first, unrelated case and was sentenced to a prison term (case one). Id. ¶ 3. He

19 appealed that conviction and remained at liberty on appeal bond. Id. Then, while out

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Related

State v. Miranda
779 P.2d 976 (New Mexico Court of Appeals, 1989)
State v. Ramzy
649 P.2d 504 (New Mexico Court of Appeals, 1982)
State v. Aaron
703 P.2d 915 (New Mexico Court of Appeals, 1985)
State v. Romero
2002 NMCA 106 (New Mexico Court of Appeals, 2002)
State v. French
2021 NMCA 052 (New Mexico Court of Appeals, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Cerda, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cerda-nmctapp-2022.