State v. Pelt

CourtNew Mexico Supreme Court
DecidedJuly 3, 2025
DocketS-1-SC-38669
StatusPublished

This text of State v. Pelt (State v. Pelt) 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.

Bluebook
State v. Pelt, (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: July 3, 2025

4 NO. S-1-SC-38669

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellant,

7 v.

8 STEVEN MIKE PELT,

9 Defendant-Appellee.

10 APPEAL FROM THE DISTRICT COURT OF SAN JUAN COUNTY 11 Daylene A. Marsh, District Judge

12 Raúl Torrez, Attorney General 13 Michael J. Thomas, Assistant Solicitor General 14 Albuquerque, NM

15 for Appellant

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

19 for Appellee 1 OPINION

2 THOMSON, Chief Justice.

3 {1} A sex offender whose sentence is deferred or suspended must “serve an

4 indeterminate period of supervised probation” ranging from five to twenty years.

5 NMSA 1978, § 31-20-5.2(A) (2003). After “the initial five years on supervised

6 probation,” and every two and one-half years thereafter, Section 31-20-5.2(B)

7 provides for a probation duration review hearing in which the state bears the burden

8 of proving to a reasonable certainty that probation should continue. This case

9 involves calculating the time a sex-offender probationer must serve in order to meet

10 the initial five-year requirement for a probation duration review hearing, pursuant to

11 Section 31-20-5.2(B).

12 {2} The State appeals from a district court order concluding that habeas petitioner

13 Steven Mike Pelt (Pelt) is entitled to a sex-offender probation duration review

14 hearing after having served more than the required five years of probation, pursuant

15 to Section 31-20-5.2(B). The State challenges the district court’s calculation of

16 probation time served for purposes of a probation duration review hearing,

17 specifically the court’s inclusion of two buckets of time during which Pelt served in-

18 house parole: (1) the time Pelt served on in-house parole after his sentence was

19 completed but before he was released into the community (Pre-Release Time) and 1 (2) the time Pelt served on in-house parole after his parole was revoked for parole

2 violations (Revocation Time). In essence, the State argues that only the time served

3 on probation in the community counts toward Pelt’s five-year probation duration

4 review hearing. Pelt asserts that the district court properly credited his Pre-Release

5 Time, but he neither contests nor concedes that the district court properly credited

6 his Revocation Time.

7 {3} To advance their positions, both parties rely primarily on the terms of our

8 general probation statute, NMSA 1978, § 31-20-5 (2003), arguing that its provisions

9 apply to sex offenders in addition to the sex-offender-specific statute, § 31-20-5.2.

10 This is for good reason; the terms of the general probation statute, if applicable,

11 provide a clear framework for calculating time served on probation for purposes of

12 a probation duration review hearing. The general probation statute provides that time

13 served on parole is credited toward time served on probation unless parole has been

14 revoked, in which case the time served on in-house parole—Revocation Time—does

15 not count toward probation. See § 31-20-5(B). However, this Court has never

16 analyzed whether both the general and the sex-offender-specific probation statutes

17 apply to sex offenders.

18 {4} We take this opportunity to answer that question in the affirmative. We hold

19 that both the general probation statute and the sex-offender-specific statute apply to

2 1 sex offenders. We further hold that, under the terms of the general probation statute,

2 § 31-20-5(B), Pre-Release Time counts toward a sex-offender probationer’s initial

3 five-year probation duration review hearing, but Revocation Time does not. Because

4 the district court included Revocation Time in its determination that Pelt is entitled

5 to a probation duration review hearing, we reverse and remand to the district court

6 with instructions to recalculate the time credited toward Pelt’s probation duration

7 review hearing in accordance with this opinion.

8 I. BACKGROUND

9 {5} On December 29, 2008, Pelt pleaded no contest to one charge of criminal

10 sexual contact with a minor under the age of thirteen, contrary to NMSA 1978,

11 Section 30-9-13(C) (2003). He was sentenced to six years in prison with three years

12 suspended and subject to an indeterminate period of mandatory supervised probation

13 pursuant to Section 31-20-5.2(A). Pelt’s three-year sentence in the New Mexico

14 Corrections Department (NMCD) ended on May 4, 2011, and his probation began

15 that same day per the order of probation, as did his parole. However, Pelt was not

16 released from NMCD to the community until May 28, 2013. Pelt remained in the

17 community until July 2, 2015, when he was arrested for violating the terms of his

18 probation. Although the State withdrew the motion and Pelt’s probation was never

19 revoked, his parole was revoked for the same underlying conduct. After serving a

3 1 period of in-house parole, Pelt was again released to the community on September

2 6, 2016. Then, on April 22, 2019, Pelt was returned to DOC pending a parole

3 violation hearing and a second parole revocation.

4 {6} While serving in-house parole following that second parole revocation, Pelt

5 petitioned for a writ of habeas corpus asserting that he was overdue for his five-year

6 parole duration review hearing and his five-year probation duration review hearing

7 and was entitled to immediate release. The district court, implicitly relying on the

8 general probation statute, § 31-20-5, and explicitly referencing the sex-offender-

9 specific probation statute, § 31-20-5.2(B), agreed that Pelt was entitled to both a

10 probation duration review hearing and a parole duration review hearing.1 The district

11 court also concluded that Pelt had served nine years and seven months on probation,

12 which accounts for both Pre-Release Time and Revocation Time. This appeal

13 followed.

1 The district court did not specify whether the probation or parole hearing should occur first, nor do we opine on that issue, as it is not before us. We take this opportunity to highlight the statute’s instruction that “the period of probation shall be served subsequent to any required period of parole.” Section 31-20-5(B)(1). It is unclear, and the parties have not addressed, what effect this provision might have on a district court’s jurisdiction to act with respect to a probationer’s term while that probationer is still serving parole and, accordingly, still subject to the Parole Board’s jurisdiction.

4 1 II. DISCUSSION

2 {7} “In appeals pertaining to habeas corpus proceedings, we defer to the district

3 court’s findings of fact if supported by substantial evidence. . . . However, we review

4 questions of law or mixed fact and law de novo.” Miller v. Tafoya, 2003-NMSC-

5 025, ¶ 9, 134 N.M. 335, 76 P.3d 1092. At its core, however, this case presents a

6 question of statutory interpretation, which the Court reviews de novo. State v.

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Bluebook (online)
State v. Pelt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-pelt-nm-2025.