State v. Sanchez

CourtNew Mexico Court of Appeals
DecidedMay 7, 2026
StatusUnpublished

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

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 Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions.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-42017

STATE OF NEW MEXICO,

Plaintiff-Appellee,

v.

JAMARI SANCHEZ,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY Douglas Driggers, District Court Judge

Raúl Torrez, Attorney General Santa Fe, NM Meryl E. Swanson, Assistant Solicitor General Albuquerque, NM

for Appellee

Bennett J. Baur, Chief Public Defender Allison H. Jaramillo, Assistant Appellate Defender Santa Fe, NM

for Appellant

MEMORANDUM OPINION

MEDINA, Chief Judge.

{1} A jury convicted Defendant Jamari Sanchez of second-degree murder, contrary to NMSA 1978, Section 30-2-1(B) (1994), and unlawful possession of a handgun by a person under age nineteen, contrary to NMSA 1978, Section 30-7-2.2 (1994, amended 2022). Defendant appeals and argues (1) the State failed to present sufficient evidence to support Defendant’s convictions; (2) the district court abused its discretion by admitting a recorded video conversation between Defendant and his mother; and (3) the district court erred in finding Defendant not amenable to treatment and in sentencing Defendant. We affirm.

DISCUSSION1

{2} The following facts were presented to a jury. Late one evening in September 2021 Victim was shot and killed. Victim’s autopsy revealed that he died from a single gunshot to his head, and Victim’s death was ruled a homicide. At trial, three witnesses testified that they were in the car with Defendant when he shot and killed Victim.

I. Sufficient Evidence Supports Defendant’s Convictions2

{3} Defendant argues that the State failed to present sufficient evidence to support his convictions because it relied on unreliable, uncorroborated accomplice testimony. Defendant recognizes, however, that uncorroborated accomplice testimony is sufficient to uphold a conviction. See State v. Gutierrez, 1965-NMSC-143, ¶ 4, 75 N.M. 580, 408 P.2d 503; State v. Kidd, 1929-NMSC-025, ¶ 3, 34 N.M. 84, 278 P. 214; State v. Montoya, 2016-NMCA-098, ¶ 24, 384 P.3d 1114. Defendant therefore requests that we certify this case to our Supreme Court to overrule existing precedent. Defendant also asks us to certify the question of whether juries should receive an instruction directing them to view the testimony of an alleged accomplice with suspicion and receive it with caution. Compare UJI 14-5015 NMRA, with id. use note (stating that no instruction on this topic should be given). Refusing to certify, we consider whether sufficient evidence supports Defendant’s convictions.

{4} “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). “Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” State v. Torres, 2018-NMSC-013, ¶ 42, 413 P.3d 467 (internal quotation marks and citation omitted). In reviewing whether sufficient evidence supports a conviction, we “view 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.

1Because this is a memorandum opinion prepared for the benefit of the parties, we provide only those facts necessary to resolve the issues raised on appeal. 2The parties dispute whether the three witnesses—the boys in the car with Defendant when he shot Victim—should be considered accomplices. Our resolution of this case does not require us to address the parties’ dispute. Assuming without deciding that the three boys were Defendant’s accomplices does not direct us to a different conclusion. {5} The district court instructed the jury on the elements of second-degree murder as follows:

For you to find [D]efendant guilty of second[-]degree murder as a lesser included offense to Count 1, the [S]tate must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime:

1. [D]efendant killed [Victim];

2. [D]efendant knew that his acts created a strong probability of death or great bodily harm to [Victim];

3. [D]efendant did not act as a result of sufficient provocation;

4. This happened in New Mexico on or about the 5th day of September, 2021.

The district court also instructed the jury on the elements of unlawful possession of a handgun by a person under age nineteen as follows:

For you to find [D]efendant guilty of unlawful possession of a handgun by a person under age 19 as charged in Count 2, the [S]tate must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime:

1. [D]efendant was in possession of a handgun;
2. [D]efendant was less than 19 years old;

3. This happened in New Mexico on or about the 5th day of September, 2021.

Both instructions contain the respective statutory elements for second-degree murder and unlawful possession of a handgun by a person under age 19. See § 30-2-1(B); § 30-7-2.2.

{6} Based on these instructions and the evidence presented at trial, we conclude that sufficient evidence supports Defendant’s convictions. As mentioned above, three witnesses testified at trial that they were with Defendant when he shot Victim. Their testimony supported a conclusion that Defendant initiated a dispute with Victim and asked one of the witnesses to hand him a gun before he shot and killed Victim.

{7} Defendant does not dispute this testimony or identify any specific elements of second-degree murder or unlawful possession of a handgun by a person under age 19 that he contends were not sufficiently proven. See State v. Gallegos, 2009-NMSC-017, ¶ 31, 146 N.M. 88, 206 P.3d 993 (explaining that it is improper for a defendant to ask the court on appeal for a blanket review of every element for every offense by failing to identify the elements or offense being challenged and by not pointing to evidence in the record to support the challenge). Instead, Defendant argues the only evidence connecting him to Victim’s death is uncorroborated accomplice testimony, which he argues is inherently unreliable. He also points to the fact that the forensic evidence could not establish that Defendant’s DNA was on the gun or on the bottles of alcohol found in the Mr. Garcia’s vehicle from the night Victim was killed. We are, however, bound by precedent, which provides that the use of uncorroborated accomplice testimony can support Defendant’s convictions. See Gutierrez, 1965-NMSC-143, ¶ 4 (“[A] defendant may be convicted on the uncorroborated testimony of an accomplice”); Kidd, 1929-NMSC-025, ¶ 3 (“The uncorroborated testimony of an accomplice is sufficient in law to support a verdict.”); Montoya, 2016-NMCA-098, ¶ 24 (refusing to depart from binding precedent that holds that uncorroborated accomplice testimony is sufficient to support a verdict).

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Related

State v. Gallegos
2009 NMSC 017 (New Mexico Supreme Court, 2009)
State v. Rudy B.
2010 NMSC 045 (New Mexico Supreme Court, 2010)
State v. Johnson
2010 NMSC 016 (New Mexico Supreme Court, 2010)
State v. Trujillo
2009 NMCA 128 (New Mexico Court of Appeals, 2009)
State v. RUDY B.
2009 NMCA 104 (New Mexico Court of Appeals, 2009)
State v. Sosa
1997 NMSC 032 (New Mexico Supreme Court, 1997)
State v. Sutphin
753 P.2d 1314 (New Mexico Supreme Court, 1988)
State v. Gutierrez
909 P.2d 751 (New Mexico Court of Appeals, 1995)
State v. JASON F.
1998 NMSC 010 (New Mexico Supreme Court, 1998)
Matter of Ernesto M., Jr.
915 P.2d 318 (New Mexico Court of Appeals, 1996)
State v. Cunningham
2000 NMSC 009 (New Mexico Supreme Court, 2000)
State v. Rojo
1999 NMSC 001 (New Mexico Supreme Court, 1998)
State v. Gutierrez
408 P.2d 503 (New Mexico Supreme Court, 1965)
State v. Gonzales
2001 NMCA 025 (New Mexico Court of Appeals, 2001)
State v. Harrison
7 P.3d 478 (New Mexico Supreme Court, 2000)
State v. Faubion
964 P.2d 834 (New Mexico Court of Appeals, 1998)
State v. JOSE S.
171 P.3d 768 (New Mexico Court of Appeals, 2007)
State v. Martinez
2002 NMCA 043 (New Mexico Court of Appeals, 2002)
State v. Kidd
278 P. 214 (New Mexico Supreme Court, 1929)
State v. Montoya
2016 NMCA 098 (New Mexico Court of Appeals, 2016)

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Bluebook (online)
State v. Sanchez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sanchez-nmctapp-2026.