State v. Maestas

CourtNew Mexico Supreme Court
DecidedMarch 20, 2025
StatusUnpublished

This text of State v. Maestas (State v. Maestas) is published on Counsel Stack Legal Research, covering New Mexico Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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State v. Maestas, (N.M. 2025).

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 SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number:

3 Filing Date: March 20, 2024

4 NO. S-1-SC-39901

5 STATE OF NEW MEXICO, 6 Plaintiff-Appellee, 7 v. 8 ALAN MAESTAS,

9 Defendant-Appellant.

10 CERTIFICATION FROM THE NEW MEXICO COURT OF APPEALS 11 Melissa A. Kennelly, District Judge

12 Kathryn Hardy Law 13 Kathryn J. Hardy 14 Taos, NM

15 for Appellant

16 Raúl Torrez, Attorney General 17 Aletheia V.P. Allen, Solicitor General 18 Santa Fe, NM

19 for Appellee 1 OPINION

2 THOMSON, Chief Justice.

3 {1} Attorney Alan Maestas was found guilty of direct punitive contempt 1 for

4 “refus[ing] to proceed to trial in defiance of the orders and warnings of the [c]ourt.”

5 The district court sanctioned Maestas to ten days in jail, with ten days suspended,

6 and to pay a $1,000 fine to the New Mexico State Bar Foundation (the Foundation).2

7 Maestas appealed, and the Court of Appeals certified to this Court the question of

8 whether a contempt fine ordered payable to a third party is permitted by statute and

9 the New Mexico Constitution. See Order of Certification to the New Mexico

10 Supreme Court, In re Maestas, No. A-1-CA-40832 (N.M. Ct. App. May 4, 2023).

11 {2} The certified question requires us to consider whether a fine payable to a third

12 party is permitted under the judiciary’s contempt power and Article VI, Section 30

1 Both the Court of Appeals in their order of certification and the parties in their briefs use the term “criminal” contempt. In accordance with In re Marshall, 2023-NMSC-009, ¶ 23, 528 P.3d 670, we use the term “punitive” contempt throughout this opinion. We reiterate that “[c]ontempt charges formerly classified as either ‘civil’ or ‘criminal’ should instead be regarded as ‘remedial’ or ‘punitive’ to more accurately reflect the distinctions between the different types of contempt.” Id. 2 The Court of Appeals affirmed the district court’s contempt finding but held that the initial sanction imposed by the district court was an abuse of discretion. In re Maestas, 2022-NMCA-057, ¶ 1, 517 P.3d 942. The sanction described here was imposed upon remand. See Judgment and Sentence on Mandate, In re Maestas, No. D-818-CR-2020-00038 (8th Jud. Dist. Ct. Nov. 03, 2022). 1 of the New Mexico Constitution. We review questions of statutory and constitutional

2 interpretation de novo. State v. Boyse, 2013-NMSC-024, ¶ 8, 303 P.3d 830.

3 {3} We hold that Maestas’s fine payable to a third party is permitted under the

4 judiciary’s inherent and uniquely broad contempt power and is constitutional. In

5 addition, the Legislature has not imposed a relevant constraint on the type of fine

6 ordered against Maestas. We also clarify that only fees collected, not fines imposed,

7 by the judicial department are subject to the limitations of Article VI, Section 30 of

8 the New Mexico Constitution.

9 I. DISCUSSION

10 A. The Fine Payable to the Foundation Is Permitted Under the Judiciary’s 11 Contempt Power

12 {4} Contempt is classified as either remedial (designed to coerce) or punitive

13 (designed to punish). In re Marshall, 2023-NMSC-009, ¶¶ 12-13. An individual can

14 be held in direct contempt for conduct committed in the presence of the court, or

15 indirect contempt for conduct committed outside the presence of the court. Id. ¶ 14.

16 In this case, Maestas was found guilty of direct punitive contempt and argues that

17 contempt fines must be paid directly to the court.

18 {5} The judiciary has inherent authority to preserve order by holding individuals

19 in contempt. State ex rel. Bliss v. Greenwood, 1957-NMSC-071, ¶ 17, 63 N.M. 156,

20 315 P.2d 223. “The real basis of [the contempt] power is to be found in the doctrine

2 1 of separation of powers as provided for . . . in the New Mexico Constitution.” Id.

2 Even without statutory authority, courts have the power to require respect, decorum,

3 and compliance with their mandates. Concha v. Sanchez, 2011-NMSC-031, ¶ 23,

4 150 N.M. 268, 258 P.3d 1060. This inherent authority is codified in NMSA 1978,

5 Section 34-1-2 (1915) which provides that “[i]t shall be within the power of each

6 and every presiding [officer] of the several courts of this state . . . to punish

7 contempt[] by reprimand, arrest, fine or imprisonment.” (Emphasis added.); see also

8 Concha, 2011-NMSC-031, ¶ 22 (“[Section 34-1-2] is declaratory of the common

9 law.” (internal quotation marks and citation omitted)).

10 {6} The judiciary’s authority to hold individuals in contempt is uniquely broad

11 and can only be constrained by the Legislature in limited circumstances. See Concha,

12 2011-NMSC-031, ¶¶ 23, 29-30. We require judges to exercise restraint to avoid

13 abuse of this uniquely broad authority. See id. ¶ 30. For example, when imposing a

14 sanction for punitive contempt, courts consider “the seriousness of the consequences

15 of the contumacious behavior, the public interest in enforcing a termination of a

16 defendant’s defiance and the importance of deterring future defiance.” State v.

17 Pothier, 1986-NMSC-039, ¶ 5, 104 N.M. 363, 721 P.2d 1294. The Legislature may

18 reasonably regulate the contempt power but may not “substantially impair or

19 destroy” it. In re Marshall, 2023-NMSC-009, ¶ 10 (internal quotation marks and

3 1 citation omitted). The only legislative constraint on the judiciary’s contempt power

2 does not apply to the facts of this case. See NMSA 1978, § 44-3-10 (1919) (limiting

3 the fine and jail sentence a court may impose for disobeying a court order to give up

4 an office if another party is deemed entitled to it in a quo warranto proceeding).

5 Significantly, this Court has, in the past, imposed a fine on an attorney payable to a

6 third party as a sanction for punitive contempt. See In re Marshall, 2023-NMSC-

7 009, ¶ 18 (affirming the appropriateness of requiring an attorney to pay a $2,000

8 punitive contempt sanction to the Client Protection Fund).

9 {7} Maestas relies on State v. Dominguez to support his argument that his

10 contempt fine must be paid directly to the court. 1993-NMCA-042, 115 N.M. 445,

11 853 P.2d 147.3 In Dominguez, the defendant was convicted of aggravated battery

3 Maestas makes other arguments related to Dominguez, but they are unclear and rely on citations to statutes that do not exist, citing for example Section 31-15- 18 and Section 31-1-18. “We will not review unclear arguments, or guess at what a party’s arguments might be.” Elane Photography, LLC v. Willock, 2013-NMSC- 040, ¶ 70, 309 P.3d 53 (brackets, internal quotation marks, and citation omitted). This Court will not consider propositions that are unsupported by citation to authority. See Wilburn v. Stewart, 1990-NMSC-039, ¶ 18, 110 N.M. 268, 794 P.2d 1197.

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