State v. DeLaO

CourtNew Mexico Court of Appeals
DecidedMay 23, 2022
StatusUnpublished

This text of State v. DeLaO (State v. DeLaO) 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. DeLaO, (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: May 23, 2022

4 No. A-1-CA-38923

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee,

7 v.

8 JUANA AMADOR DELAO,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF OTERO COUNTY 11 Steven Blankinship, District Judge

12 Hector H. Balderas, Attorney General 13 Maris Veidemanis, Assistant Attorney General 14 Santa Fe, NM

15 for Appellee

16 Bennett J. Baur, Chief Public Defender 17 MJ Edge, Assistant Appellate Defender 18 Santa Fe, NM

19 for Appellant 1 OPINION

2 WRAY, Judge.

3 {1} Defendant Juana Amador DeLaO appeals her convictions for four counts of

4 fraud, contrary to NMSA 1978, Section 30-16-6(E) (2006), and thirteen counts of

5 failing to disclose facts to obtain public assistance, contrary to NMSA 1978, Section

6 30-40-1(D), (E) (2006). 1 The charges related to Defendant’s application for and

7 receipt of several forms of public assistance benefits: Supplemental Security Income

8 (SSI), Social Security Disability Insurance (SSDI), Medicaid, and food stamps

9 (SNAP). Defendant invites us to reverse her convictions based on her contentions

10 that the charges under Section 30-16-6 and Section 30-40-1 are either entirely

11 preempted by federal law or they are duplicative. Alternatively, Defendant seeks

12 remand for “a new and fair trial before a properly instructed jury.” We conclude that

13 under these circumstances, convictions pursuant to both Section 30-16-6 (fraud) and

14 Section 30-40-1 (failure to disclose facts to obtain public assistance) impose multiple

15 unsanctioned punishments. We therefore affirm in part, reverse in part, and remand

16 for the district court to vacate Defendant’s convictions under Section 30-40-1.

17 Otherwise, we affirm.

1 The State charged eighteen counts and dismissed one count before trial. The counts were renumbered in the jury instructions and the verdicts. In this opinion, we generally refer to the renumbered counts that the jury considered and decided. 1 BACKGROUND

2 {2} At the outset, we provide general background for SSI, SSDI, Medicaid, and

3 SNAP benefits. SSI “is a federal income maintenance program for the aged, blind,

4 or disabled” and eligibility is based on “need and a showing that the applicant’s

5 earning capacity is impaired by either age, blindness or other disability.” Sheets v.

6 Sheets, 1987-NMCA-128, ¶ 15, 106 N.M. 451, 744 P.2d 924. To qualify, the

7 applicant must show income “below the statutory maximum” and awarded benefits

8 “are subject to periodic review.” Id. SSDI, however, is “an earned insurance

9 proceed” that is “directly related to the amount the insured has paid into the

10 program.” In re Marriage of Taber, 280 P.3d 234, 238 (Kan. Ct. App. 2012). A

11 person who has “previously worked and contributed to the program by paying taxes

12 on earned income” is entitled to benefits if she subsequently “suffer[s] from a

13 physical or mental disability and [is] no longer able to work.” Id. Medicaid is a

14 “federal-state program providing medical services to the needy.” Starko, Inc. v.

15 Gallegos, 2006-NMCA-085, ¶ 2, 140 N.M. 136, 140 P.3d 1085. New Mexico has

16 adopted a “managed care system to provide cost-efficient, preventive, primary and

17 acute care for medicaid recipients.” NMSA 1978, § 27-2-12.6(A) (1994). The state

18 contracts with other entities, “which in turn provide health care to Medicaid

19 recipients.” Starko, 2006-NMCA-085, ¶ 3. Last, SNAP is “a federal-state program,”

20 8.139.100.9(A) NMAC, that is “designed to promote the general welfare and to

2 1 safeguard the health and well-being of the nation’s population by raising the levels

2 of nutrition among low-income households.” 8.139.100.11(A) NMAC. With this as

3 background, we turn to the facts of the present case.

4 {3} The evidence at trial established that in 2012, Defendant submitted an

5 application for and received SSI and SSDI benefits. Defendant reported either only

6 social security income or did not disclose a current employer. As a result of her SSI

7 application, Defendant additionally was determined to be eligible for Medicaid and

8 received Medicaid benefits. In late 2013, Defendant also applied for SNAP benefits

9 but reported no income or employment on those applications. Defendant, however,

10 had income and was working for Dollar Cab between 2009 and 2012, and again

11 between 2013 and 2017.

12 {4} Defendant received SSDI, SSI, and Medicaid benefits between 2012 and

13 2017, and SNAP benefits between 2013 and 2017. Defendant, as a recipient of

14 benefits from each of these programs, was obligated to report any income or

15 employment changes to administering agencies. Despite reapplications and notice

16 of her ongoing reporting obligations, Defendant did not report her Dollar Cab

17 income or employment during the period that she received benefits from each of the

18 programs. In 2018, Defendant was charged with multiple counts of fraud and failure

19 to disclose facts to obtain public assistance. The jury convicted Defendant on all

20 counts. Defendant appeals.

3 1 DISCUSSION

2 {5} On appeal, Defendant argues that (1) the multiple convictions violate double

3 jeopardy, and (2) the district court improperly refused to instruct the jury on mistake

4 of fact. 2 We address each of these arguments in turn.

5 I. Double Jeopardy

6 {6} Defendant contends that the jury’s seventeen convictions violate

7 constitutional double jeopardy protections. We review double jeopardy claims de

8 novo. State v. Bernal, 2006-NMSC-050, ¶ 6, 140 N.M. 644, 146 P.3d 289. In the

9 context of the present case, double jeopardy protections prevent citizens from being

10 subject to multiple punishments. See id. ¶ 7. “Multiple punishment problems can

11 arise from both ‘double-description’ claims, in which a single act results in multiple

2 Defendant additionally argues that the entire state prosecution was preempted by federal law. Federal preemption is a principle arising from “the basic structure of our federal system,” dual state and federal sovereignty, and the limits placed on the states by the Supremacy Clause of the United States Constitution. State v. Herrera, 2014-NMCA-003, ¶ 6, 315 P.3d 311 (internal quotation marks and citation omitted). Federal preemption can be express or implied, and two distinct forms of implied preemption involve two separate well-established analyses. Id. ¶¶ 7, 9. All this to say, preemption is complicated. Defendant, however, neither identified an applicable form of preemption nor applied any specific preemption analysis to the particular statutes at issue in this case. Defendant has extensively set forth the law of federal preemption, but has not sufficiently developed any argument that allows us to apply the law to the circumstances of this case without significant extrapolation.

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State v. DeLaO, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-delao-nmctapp-2022.