State v. Fulton

CourtNew Mexico Court of Appeals
DecidedOctober 9, 2025
DocketA-1-CA-41026
StatusPublished

This text of State v. Fulton (State v. Fulton) 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. Fulton, (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: October 9, 2025

4 No. A-1-CA-41026

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee,

7 v.

8 JOHNNY D. FULTON,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY 11 Richard M. Jacquez, District Court Judge

12 Raúl Torrez, Attorney General 13 Santa Fe, NM 14 Charles J. Gutierrez, Assistant Solicitor General 15 Albuquerque, NM

16 for Appellee

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

20 for Appellant 1 OPINION

2 IVES, Judge.

3 {1} A jury found Defendant Johnny D. Fulton guilty of child abuse by

4 endangerment in violation of NMSA 1978, Section 30-6-1(D) and (E) (2009).

5 Defendant’s primary argument on appeal is that the district court deprived him of

6 his Sixth Amendment right to an impartial jury when it denied his motions to

7 disqualify three potential jurors for cause and then denied his motion for a mistrial.

8 We conclude that Defendant has not established error with respect to either type of

9 actual bias: express bias or inferable bias. None of the jurors’ statements amounted

10 to express bias—a type of bias that requires disqualification as a matter of law—and

11 their statements, considered in context, did not compel the district court to exercise

12 its discretion to infer bias. As to Defendant’s other arguments on appeal, we are not

13 persuaded that the district court erred by denying Defendant’s motion for a mistrial

14 based on the admission of testimony that Defendant contends was inadmissible

15 evidence of prior bad acts under Rule 11-404(B) NMRA. Nor are we persuaded that

16 the district court erred by denying Defendant’s motion for a new trial based on his

17 claim that the jury pool was composed in a manner that violated NMSA 1978,

18 Section 38-5-3 (2011). We therefore affirm. 1 BACKGROUND

2 {2} We begin with a brief background to provide general context, reserving

3 detailed descriptions of the distinct facts relevant to each claim of error. During a

4 jury trial, the State presented evidence that Defendant and his family were together

5 on November 25, 2020, preparing for Thanksgiving. At one point, while Defendant

6 and his minor child, U.F., were playing a game, U.F. jokingly choked Defendant.

7 This angered Defendant. He told U.F. not to do that and then he began to choke U.F.

8 After letting go, Defendant asked U.F. if he understood, but U.F. did not respond.

9 Defendant began to choke U.F. a second time. After letting go the second time,

10 Defendant asked again if U.F. understood, and U.F. responded affirmatively. Based

11 on these two incidents of choking, the jury found Defendant guilty of one count of

12 child abuse.

13 DISCUSSION

14 I. Defendant Was Not Deprived of His Sixth Amendment Right to a Fair 15 and Impartial Jury

16 {3} Defendant argues that the district court erred by denying his motions to strike

17 three members of the jury pool—Jurors 12, 24, and 51—for cause and his motion

18 for a mistrial because the jurors’ responses to questions during jury selection

19 established actual bias that disqualified them from serving on the jury. According to

20 Defendant, these errors deprived him of his Sixth Amendment right to a fair and

21 impartial jury. We disagree. As we will explain, Defendant did not establish express 1 bias, which would have barred the potential jurors from serving as a matter of law.

2 The jurors’ statements instead required the district court to decide, based on the

3 evidence developed during jury selection, whether to infer that each juror was

4 biased. We conclude that the district court did not abuse its discretion by declining

5 to infer that any of these three jurors was biased.

6 {4} We begin our analysis by describing the pertinent features of New Mexico’s

7 legal framework for analyzing claims of juror bias. We then apply that framework

8 to Defendant’s case, first analyzing Defendant’s claims that Jurors 24 and 51 made

9 statements amounting to express bias that required disqualification as a matter of

10 law and then analyzing whether the district court abused its discretion by declining

11 to infer bias as to Jurors 12, 24, and 51.

12 A. New Mexico’s Legal Framework for Juror Bias

13 {5} Although questions regarding juror bias are far from new to New Mexico’s

14 appellate courts, see Territory v. Emilio, 1907-NMSC-020, ¶¶ 13-25, 14 N.M. 147,

15 89 P. 239, our state’s current legal framework for analyzing such questions is just

16 two years old. That framework was articulated by our Supreme Court in State v.

17 Romero, 2023-NMSC-014, 533 P.3d 735, which divides juror bias into two

18 categories. The first category, implied bias, mandates disqualification based on the

19 nature of a juror’s relationship to a person who plays an important role in the case,

20 such as a party, lawyer, or witness. See id. ¶¶ 12-14, 20-21. Implied bias is not at 1 issue in Defendant’s appeal. His appeal presents questions involving the second

2 category, actual bias, of which there are two types in New Mexico: express bias and

3 inferable bias. 1 See id. ¶¶ 9-11, 16-19. Romero requires courts to analyze each type

4 of actual bias in a different way. Id.

5 {6} Express bias analysis involves clear, simple rules. Express bias exists only if

6 a potential juror makes “an unequivocal statement” that they “cannot be fair and

7 impartial.” Id. ¶ 10. Whether a particular statement satisfies this test may sometimes

8 be debated. See State v. Holtsoi, 2024-NMCA-042, ¶¶ 7-10, 547 P.3d 770. But if

9 express bias is established, a bright-line rule applies: The Sixth Amendment of the

10 United States Constitution requires disqualification of the prospective juror.

11 Romero, 2023-NMSC-014, ¶ 10; accord State v. Medema, 2025-NMCA-011, ¶ 13,

1 Although Romero adopts certain principles from out-of-jurisdiction precedents, including precedents from federal circuit courts, our Supreme Court chose not to adopt the entire legal framework described in any of the cited precedents. As relevant here, Romero categorizes inferable bias as a type of actual bias, 2023-NMSC-014, ¶¶ 11, 19, while the Second Circuit case on which Romero relies for inferable bias principles, United States v. Torres, 128 F.3d 38 (2d Cir. 1997), treats inferable bias as a third broad category of bias—separate and distinct from actual bias and implied bias. Id. at 43 (describing actual bias as bias in fact and identifying two types of actual bias—bias expressly admitted by a juror and bias found by the judge based on a juror’s answers during jury selection); id. at 45-46 (describing implied bias); id. at 46-47 (explaining that inferable bias is a third category of bias that exists in a few circumstances that “involve no showing of actual bias” and “that fall outside of the implied bias category”).

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