State v. Crespin

CourtNew Mexico Court of Appeals
DecidedDecember 18, 2025
StatusUnpublished

This text of State v. Crespin (State v. Crespin) 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. Crespin, (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 Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions.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-41613

STATE OF NEW MEXICO,

Plaintiff-Appellee,

v.

ADAM FRANK CRESPIN,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF CURRY COUNTY Ben Cross, District Court Judge

Raúl Torrez, Attorney General Felicity Strachan, Assistant Solicitor General Santa Fe, NM

for Appellee

Wadsworth Law, LLC Mathew R. Wadsworth Rio Rancho, NM

for Appellant

MEMORANDUM OPINION

YOHALEM, Judge.

{1} Defendant was convicted of battery upon a peace officer, contrary to NMSA 1978, § 30-22-24 (1971); and resisting, evading or obstructing an officer (arrest), contrary to NMSA 1978, § 30-22-1(B) (1981). Defendant appeals only his conviction of battery upon a peace officer, claiming that (1) the jury’s determination that he “intentionally touched or applied force to [the officer] by elbowing him in the face and pushing him to the ground” is not supported by substantial evidence; (2) the district court’s admission of Defendant’s drug use was plain error under Rules 11-402, 11-403, and 11-404 NMRA; (3) the State committed prosecutorial misconduct in its closing arguments by referring to evidence of Defendant’s drug use; (4) Defendant’s counsel failed to provide effective assistance; and (5) the district court failed to make statutorily required findings to sentence Defendant as a serious violent offender. We reverse and remand for reconsideration of the serious violent offender determination. We otherwise affirm.

DISCUSSION

{2} This is a memorandum opinion. We have not included a background section, and instead discuss the facts relevant to each issue in our discussion of that issue. Because the parties are familiar with the facts and procedural posture of the case, we set forth only such facts and law as are necessary to decide the issues raised.

I. Sufficient Evidence Supports Defendant’s Conviction of Battery Upon a Peace Officer

{3} Defendant first challenges the sufficiency of the evidence supporting his conviction of battery upon a peace officer. Defendant argues that he did not intentionally touch or apply force to Officer Cope, claiming that there was no evidence to support the jury’s findings that Defendant pushed the officer to the ground or that he intentionally, rather than accidently, elbowed the officer in the face. Defendant claims that Officer Cope pushed Defendant to the ground, rather than Defendant pushing the officer, and that Defendant’s “elbow happened to make contact with [the officer’s] face.” 1 We conclude that the evidence was sufficient to support the jury’s findings that Defendant pushed the officer to the ground and intentionally elbowed him in the face.

{4} “The test for sufficiency of the evidence is whether substantial evidence of either a direct or circumstantial nature exists to support a verdict of guilty beyond a reasonable doubt with respect to every element essential to a conviction.” State v. Ford, 2019- NMCA-073, ¶ 7, 453 P.3d 471 (internal quotation marks and citation omitted). We “view the evidence in the light most favorable to the guilty verdict, indulging all reasonable inferences and resolving all conflicts in the evidence in favor of the verdict.” See State v. Cunningham, 2000-NMSC-009, ¶ 26, 128 N.M. 711, 998 P.2d 176. In doing so, this Court “[does] not re-weigh the evidence to determine if there was another hypothesis that would support innocence.” See State v. Garcia, 2005-NMSC-017, ¶ 12, 138 N.M. 1, 116 P.3d 72. The relevant question is whether “any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” See State v. Holt, 2016-NMSC-011, ¶ 20, 368 P.3d 409 (internal quotation marks and citation omitted).

1The State defends against an additional argument in its answer brief on appeal: it claims there was sufficient evidence to support the jury’s finding that Defendant knew that Officer Cope was a peace officer. Because Defendant does not challenge this finding on appeal, we do not address the State’s argument. {5} “Jury instructions become the law of the case against which the sufficiency of the evidence is to be measured.” State v. Smith, 1986-NMCA-089, ¶ 7, 104 N.M. 729, 726 P.2d 883. In this case, the jury was instructed that the State must prove beyond a reasonable doubt that “[D]efendant intentionally touched or applied force to [the officer] by elbowing him in the face and pushing him to the ground.”

{6} The jury was also given the New Mexico Uniform Jury Instruction on general criminal intent, UJI 14-141 NMRA. The jury was instructed in relevant part as follows:

A person acts intentionally when he purposely does an act which the law declares to be a crime even though he may not know that his act is unlawful. Whether [D]efendant acted intentionally may be inferred from all of the surrounding circumstances, such as the manner in which he acts, the means used, and his conduct and any statements made by him.

{7} In Defendant’s argument on sufficiency of the evidence, he does not challenge the court’s decision to instruct the jury solely on general criminal intent.2 Defendant argues that he did not have the general intent required by UJI 14-141 because he “made incidental, unintentional contact with [Officer] Cope.” Defendant’s primary argument is that the evidence presented by the State was insufficient to allow a rationale juror, applying the general intent instruction given by the district court, to find that Defendant acted intentionally in elbowing Officer Cope in the face.

{8} The general intent instruction, quoted above, requires the jury to find that Defendant purposely performed the alleged action. In other words, Defendant must have intended to perform the action of striking the officer with his elbow. An argument that Defendant’s elbow accidently made contact with the officer states a valid defense to a general intent requirement. Defendant’s reason for striking the officer, however, is not relevant to general intent to touch or exert force on the officer. Defendant’s argument that he just wanted to get away, or that he did not want to fight with or injure the officer does not make his act unintentional under the relevant general intent jury instruction.

2The defense, in its argument on appeal on prosecutorial misconduct, questions the absence of a specific intent instruction. Neither party sought a specific intent instruction as to any element of the battery on a peace officer charge or argued that the general intent instruction failed to adequately apprise the jury of the relevant law. Although there may be an argument that some element of battery upon a peace officer requires specific intent, the sole element disputed at trial was Defendant’s intent to touch or apply force to the officer. The application of general intent to this element of the crime is consistent with our law on battery, which provides that the intent to touch or apply force to another requires only general intent. See State v. Skippings, 2011-NMSC-021, ¶ 14, 150 N.M. 216, 258 P.3d 1008 (“[T]he simple battery statute only requires that the perpetrator possess general criminal intent to touch or apply force to the person of another, when done in a rude, insolent or angry manner.” (internal quotation marks and citation omitted)).

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