State v. Ott

CourtNew Mexico Court of Appeals
DecidedDecember 31, 2025
StatusUnpublished

This text of State v. Ott (State v. Ott) 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. Ott, (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 Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions.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-42384

STATE OF NEW MEXICO,

Plaintiff-Appellee,

v.

JAMES OTT,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF OTERO COUNTY Stephen Ochoa, District Court Judge

Raúl Torrez, Attorney General Santa Fe, NM Michael J. Thomas, Assistant Solicitor General Albuquerque, NM

for Appellee

Bennett J. Baur, Chief Public Defender Melanie C. McNett, Assistant Appellate Defender Santa Fe, NM

for Appellant

MEMORANDUM OPINION

DUFFY, Judge.

{1} This matter was submitted to the Court on Defendant’s brief in chief pursuant to the Administrative Order for Appeals in Criminal Cases from the Second, Eleventh, and Twelfth Judicial District Courts in In re Pilot Project for Criminal Appeals, No. 2022-002, effective November 1, 2022. Following consideration of the brief in chief, the Court assigned this matter to Track 2 for additional briefing. Now having considered the brief in chief, the answer brief, and the reply brief, we affirm for the following reasons. {2} Defendant appeals his convictions for criminal damage to property, assault on a peace officer, and resisting, evading, or obstructing a peace officer. [RP 202] Defendant argues that the State failed to present sufficient evidence of the value of the damaged property to support a felony conviction for criminal damage to property, and the jury instruction defining “amount of damage” was improper. Defendant also argues that his convictions for both resisting, evading, and obstructing and assault on a peace officer violate double jeopardy. For the following reasons, we affirm.

{3} We first consider Defendant’s challenge to the sufficiency of the evidence. “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. Montoya, 2015-NMSC- 010, ¶ 52, 345 P.3d 1056 (internal quotation marks and citation omitted). The reviewing court “view[s] 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.” State v. Cunningham, 2000-NMSC-009, ¶ 26, 128 N.M. 711, 998 P.2d 176. We disregard all evidence and inferences that support a different result. See State v. Rojo, 1999-NMSC-001, ¶ 19, 126 N.M. 438, 971 P.2d 829.

{4} In order to convict Defendant of felony criminal damage to property, the State was required to prove Defendant intentionally damaged the property of another without consent and the amount of damage exceeded $ 1,000. See NMSA 1978, § 30-15-1 (1963) (defining criminal damage to property); UJI 14-1501 NMRA (stating elements). Defendant does not contest that he repeatedly kicked the rear passenger door of a police vehicle as he was being transported to jail and that this caused damage. Rather, Defendant argues that the State failed to present sufficient evidence that the amount of damage to the property exceeded $1,000. [BIC 11-19; RB 3-5]

{5} For purposes of a criminal damage to property charge, the amount of damage is calculated as either “the difference between the price at which the property could ordinarily be bought or sold prior to the damage and the price at which the property could be bought or sold after the damage,” UJI 14-1510 NMRA, or “the cost of repair or replacement, whichever is less.” State v. Fierro, 2024-NMCA-016, ¶ 8, 542 P.3d 802 (internal quotation marks and citation omitted).

{6} At trial, Johnny Whitlock, the owner and operator of an auto body shop, testified that he repaired the damage to the door, and the State introduced an itemized receipt for the repair in the amount of $3,412.06. [6/3/2024 FTR 2:52:03-2:55:15; BIC 14] Officer Jantzen Duran testified that the vehicle was a 2014 Ford Explorer that was regularly maintained and in good condition. Officer Duran also testified that the vehicle was fitted with specialized police equipment including lights, sirens, bars on the windows, and a cage in the back. [6/3/2024 FTR 2:18:00-2:21:49] Mr. Whitlock additionally testified that the vehicle was worth more than the cost of the repair. [6/3/2024 FTR 2:55:30-45] {7} Defendant argues that the State was required to prove the replacement cost of the vehicle in addition to the cost of repair to establish the amount of damage. [BIC 14- 19] We disagree. Generally, because the measure of damage is the lesser of the cost of repair or the cost of replacement, whichever is less, see State v. Cobrera, 2013-NMSC- 012, ¶ 8, 300 P.3d. 729, we have required the State to produce evidence of both the repair and the replacement cost so that the jury can compare them. However, we have recognized that evidence of replacement cost may not be required when an average juror would know that the replacement cost of the damaged item is well over the cost to repair the damage. See State v. Barreras, 2007-NMCA-067, ¶ 9, 141 N.M. 653, 159 P.3d 1138. In Barreras, the defendant damaged a one-year-old Cadillac Escalade that had been in good condition. Id. We rejected the defendant’s argument that the state was required to present evidence of the replacement cost of the vehicle and held that the jury could infer that the replacement cost exceeded the $5,100 cost of the repairs, reasoning the jurors “would know that such a high-end sport utility vehicle has a replacement cost well over $5,100.” Id.

{8} However, we cautioned in Barreras that “[e]vidence of replacement cost may be necessary where the vehicle is older and/or made by a lesser-named manufacturer.” Id. Thus, in State v. Fernandez, we held that the state was required to present evidence of both the repair and the replacement cost of a damaged pickup truck because “the ‘average juror’ had no basis upon which to determine that the replacement cost of [the victim’s] pickup truck, which was over a decade old and had noticeable preexisting damage, would be ‘well over’ the $1[,]500 cost of repair.” 2015-NMCA-091, ¶ 10, 355 P.3d 858 (quoting Barreras, 2007-NMCA-067, ¶ 9).

{9} The circumstances in this case are more like those presented in Barreras. Here, the State presented evidence that the Ford Explorer was only seven years old at the time of the damage, in cosmetically good condition, well-maintained, and outfitted with specialized police equipment. [BIC 16] Additionally, Mr. Whitlock testified, without objection, that the vehicle was worth more than the cost of the repair work done. Based on this evidence, the jury could reasonably conclude that the replacement cost of the vehicle exceeded the cost of repair, and the State was not required to present further evidence of the cost of replacement. See Barreras, 2007-NMCA-067, ¶ 9; see also Fernandez, 2015-NMCA-091, ¶ 9 (“In some cases, . . . the facts may clearly establish that the replacement cost would exceed the cost of repair and no additional evidence or testimony may be required; nonetheless, the replacement cost remains part of the [s]tate’s burden.”).

{10} Defendant next argues that it was reversible error for the district court to omit part of the definitional instruction on “amount of damage” from the instructions provided to the jury. [BIC 19-23] “The standard of review we apply to jury instructions depends on whether the issue has been preserved. If the error has been preserved[,] we review the instructions for reversible error. If not, we review for fundamental error.

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Related

State v. Cobrera
2013 NMSC 12 (New Mexico Supreme Court, 2013)
State v. Swick
2012 NMSC 18 (New Mexico Supreme Court, 2012)
State v. Cunningham
2000 NMSC 009 (New Mexico Supreme Court, 2000)
State v. Rojo
1999 NMSC 001 (New Mexico Supreme Court, 1998)
State v. Franco
2005 NMSC 13 (New Mexico Supreme Court, 2005)
State v. Andazola
2003 NMCA 146 (New Mexico Court of Appeals, 2003)
State v. DeGraff
2006 NMSC 011 (New Mexico Supreme Court, 2006)
State v. Contreras
156 P.3d 725 (New Mexico Court of Appeals, 2007)
State v. Barrera
2001 NMSC 014 (New Mexico Supreme Court, 2001)
State v. Benally
2001 NMSC 033 (New Mexico Supreme Court, 2001)
State v. Ford
2007 NMCA 052 (New Mexico Court of Appeals, 2007)
State v. Melendrez
2014 NMCA 62 (New Mexico Court of Appeals, 2014)
State v. Gwynne
417 P.3d 1157 (New Mexico Court of Appeals, 2018)
State v. Montoya
2015 NMSC 010 (New Mexico Court of Appeals, 2015)
State v. Franco
2005 NMSC 013 (New Mexico Supreme Court, 2005)
State v. Contreras
2007 NMCA 045 (New Mexico Court of Appeals, 2007)
State v. Barreras
2007 NMCA 067 (New Mexico Court of Appeals, 2007)
State v. Jackson
2020 NMCA 034 (New Mexico Court of Appeals, 2020)
State v. Reed
2022 NMCA 025 (New Mexico Court of Appeals, 2021)
State v. Phillips
548 P.3d 51 (New Mexico Supreme Court, 2024)

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