State v. Lovato

CourtNew Mexico Court of Appeals
DecidedMarch 24, 2026
StatusPublished

This text of State v. Lovato (State v. Lovato) 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. Lovato, (N.M. Ct. App. 2026).

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: March 24, 2026

4 No. A-1-CA-42347

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee,

7 v.

8 MARCUS LOVATO,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY 11 Britt M. Baca, District Court Judge

12 Raúl Torrez, Attorney General 13 Santa Fe, NM 14 Tyler Sciara, Assistant Solicitor General 15 Albuquerque, NM

16 for Appellee

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

20 for Appellant 1 OPINION

2 HENDERSON, Judge.

3 {1} Defendant Marcus Lovato appeals his convictions for two counts of criminal

4 sexual penetration (CSP) in the second degree, contrary to NMSA 1978, Section 30-

5 9-11(E)(4) (2009); conspiracy to commit CSP in the second degree, contrary to

6 NMSA 1978, Section 30-28-2 (1979) and Section 30-9-11(E)(4); attempt to commit

7 CSP in the second degree, contrary to NSMA 1978, Section 30-28-1 (1963, amended

8 2024) 1 and Section 30-9-11(E)(4); criminal sexual contact (CSC) in the fourth

9 degree, contrary to NMSA 1978, Section 30-9-12(A), (C) (1993); and voyeurism,

10 contrary to NMSA 1978, Section 30-9-20 (2007). On appeal, Defendant makes

11 multiple claims that his various convictions violate his right to be free from double

12 jeopardy, and argues that the district court erred in denying his requests for a jury

13 instruction on duress. Concluding that Defendant’s convictions do not violate double

14 jeopardy and that Defendant failed to make a prima facie showing of duress, we

15 affirm.

1 Defendant’s acts occurred on June 4, 2021, before the statute was amended in 2024. We use the original statute throughout, as that was the statute in effect at the time Defendant was charged, and the 2024 amendment is not relevant to our analysis. 1 BACKGROUND

2 {2} On June 3, 2021, Defendant and his friend rented a motel room that was next

3 door to a room that the codefendant, Isadore Gordon and Victim had rented. The

4 pairs did not know each other and first met when they had a conversation on the

5 shared motel balcony. The codefendant repeatedly invited Defendant to have a drink

6 with him and Victim, and Defendant eventually agreed after the codefendant came

7 to Defendant’s room to ask. Defendant testified that while they were drinking on the

8 balcony, the codefendant told Defendant to go into the codefendant’s room because

9 Victim needed to show him something. Defendant entered the codefendant’s room

10 and heard loud noises coming from the bathroom, Victim then stumbled out of the

11 bathroom and passed out on the bed.

12 {3} Once in the room, the codefendant testified that he flirted with Defendant,

13 their conversation became sexual in nature, and they kissed. Defendant testified that

14 he was scared because the codefendant was blocking the door and had threatened

15 him that on codefendant’s tribal reservation, “his kind of people know how to get

16 rid of people,” and that if Defendant did not do what the codefendant told him to do

17 that he would “take [Defendant] out there and have [him] go missing.” Both parties

18 testified that the codefendant then told Defendant to perform sexual acts on Victim,

19 who was now “passed out” and “flopped” over on the bed, while the codefendant

20 recorded the acts on his cell phone. The codefendant recorded twenty-two 1 noncontinuous videos showing acts occurring in the codefendant and Victim’s motel

2 room, which were admitted as evidence and timestamped for varying durations

3 between 1:13:47 a.m. and 4:09:16 a.m. on June 4, 2021. The codefendant testified

4 that the videos were not continuous, such that there were moments not captured on

5 video. Defendant testified that he repeatedly asked to leave the room to get lube and

6 to shower as excuses to get out of the situation, but was told he could not leave by

7 the codefendant. Defendant also testified that after he performed the acts with

8 Victim, the codefendant sexually assaulted him, and he was only able to leave the

9 room after the codefendant drunkenly fell over.

10 {4} Defendant testified that after he left the codefendant’s motel room he returned

11 to his own room in a panicked state and his friend called the police. The police

12 arrived to investigate and Defendant attended a sexual assault nurse examination

13 (SANE) interview that day. Victim testified that he had no memory of the events

14 after he had blacked out in the motel room. Victim also attended a SANE interview

15 approximately one month later, but bodily fluids could not be recovered or analyzed

16 given the time that had elapsed since the sexual assault. During the investigation, the

17 police extracted the videos from the codefendant’s phone, and Defendant and the

18 codefendant became co-suspects. As a result, Defendant was indicted on four counts

19 of CSP, one count of conspiracy to commit CSP, one count of attempted CSP, one

20 count of CSC, one count of voyeurism, and one count of making a false report in 1 June 2021. 2 The codefendant accepted a plea deal conditioned on him testifying

2 against Defendant.

3 {5} At trial, the State called Victim, the codefendant, the responding officer, the

4 detective on the case, and Victim’s SANE nurse to testify. At the close of the State’s

5 evidence, the district court granted Defendant’s motion for a directed verdict on

6 Count 1 and the remaining counts were renumbered. Defendant also requested a jury

7 instruction on duress, which was denied on grounds that Defendant had not

8 introduced evidence of fear of imminent bodily harm. Defendant then testified

9 during his case in chief that he only performed the sexual acts on Victim out of fear

10 of the codefendant. Following this testimony, Defendant again requested a jury

11 instruction on duress. The district court again denied his request, finding that

12 Defendant had not shown that he was in fear of imminent danger, did not admit to

13 the offenses, and did not act reasonably. The jury returned a verdict finding

14 Defendant guilty of Count 2, CSP by anal penetration; Count 3, CSP by fellatio;

15 Count 4, conspiracy to commit CSP; Count 5, attempt to commit CSP; Count 6,

16 CSC; and Count 7, voyeurism. The jury found Defendant not guilty of Count 1, CSP

17 by anal penetration. Defendant later filed a motion for a new trial on grounds that

18 the district court erred by denying his request for a jury instruction on duress. The

2 Prior to trial, the State entered a nolle prosequi for the count of making a false report, contrary to NMSA 1978, Section 30-39-1 (1979). 1 district court denied his motion, again finding that Defendant did not make a

2 sufficient showing of duress. Defendant now appeals his convictions.

3 DISCUSSION

4 {6} On appeal, Defendant contends that (1) his various convictions violate his

5 right to be free from double jeopardy on both unit of prosecution and double

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State v. Lovato, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-lovato-nmctapp-2026.