State v. Sloan

CourtNew Mexico Supreme Court
DecidedJune 23, 2016
Docket34,858
StatusUnpublished

This text of State v. Sloan (State v. Sloan) 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. Sloan, (N.M. 2016).

Opinion

This decision was not selected for publication in the New Mexico Appellate Reports. Please see Rule 12-405 NMRA for restrictions on the citation of non-precedential dispositions. Please also note that this electronic decision may contain computer-generated errors or other deviations from the official paper version filed by the Supreme Court.

1 IN THE SUPREME COURT OF THE STATE OF NEW MEXICO

2 Filing Date: June 23, 2016

3 STATE OF NEW MEXICO,

4 Plaintiff-Appellee,

5 v. NO. S-1-SC-34858

6 MATTHEW SLOAN,

7 Defendant-Appellant.

8 APPEAL FROM THE DISTRICT COURT OF EDDY COUNTY 9 Lisa B. Riley, District Judge

10 Bennett J. Baur, Chief Public Defender 11 Tania Shahani, Assistant Appellate Defender 12 Santa Fe, NM

13 for Appellant

14 Hector H. Balderas, Attorney General 15 Joel Jacobsen, Assistant Attorney General 16 Santa Fe, NM

17 for Appellee

18 DISPOSITIONAL ORDER OF REVERSAL 1 VIGIL, Justice.

2 {1} This direct appeal having come before the full Court, the Justices having read

3 the briefs of the parties and otherwise having fully informed themselves on the issues

4 and applicable law as raised by the parties; and

5 {2} All of the Justices having concurred that there is no reasonable likelihood that

6 a written decision or opinion would affect the disposition of this appeal or advance the

7 law of the state;

8 IT IS, THEREFORE, ADJUDGED THAT:

9 {3} Defendant appeals from his convictions for felony murder, burglary, and

10 tampering with evidence. Defendant raises three issues on appeal. Defendant’s first

11 issue raises a number of challenges to the jury instructions as a matter of fundamental

12 error. Defendant’s second issue raises a claim of ineffective assistance of counsel

13 arising from the erroneous jury instructions given in this case. And Defendant’s third

14 issue challenges the district court’s denial of Defendant’s motion to suppress evidence

15 based on Defendant’s claims of a faulty search warrant process. For the reasons that

16 follow, we reverse Defendant’s convictions for felony murder and burglary, affirm his

17 conviction for tampering with evidence, and remand for a new trial.

18 Defendant’s Convictions for Felony Murder and Burglary Must Be Reversed and 19 Remanded for a New Trial Because of Errors in the Instructions Given to the

2 1 Jury

2 {4} Defendant argues that the jury was erroneously instructed because (1) the

3 essential elements instruction for the felony murder charge did not include the

4 essential elements of the predicate offense of attempted armed robbery; (2) the

5 intoxication instruction given with the felony murder charge also refers to attempted

6 armed robbery but fails to accurately set forth the intent element for that crime; (3) the

7 duress instruction given to the jury refers to both attempted robbery and armed

8 robbery but does not define either crime; (4) the aggravated burglary instruction uses

9 armed robbery as the predicate offense but does not set forth the elements of the

10 crime; (5) the intoxication instruction given with the aggravated burglary charge refers

11 to an unparticularized felony and refers to “theft” even though theft was not included

12 as a basis for aggravated burglary; and (6) the lesser-included offense of burglary uses

13 robbery as the predicate felony even though the court did not provide the jury with the

14 essential elements for that crime.

15 Felony Murder and Related Instructions Fail to Provide the Essential Elements 16 for the Predicate Offense of Attempted Armed Robbery

17 {5} The State concedes error in the felony murder instruction because the essential

18 elements of the predicate offense, attempted armed robbery, were not given. And

19 although the intoxication and duress instructions that were given with the felony

3 1 murder instruction reference the predicate felony of attempted armed robbery, neither

2 of those instructions sets forth the essential elements for attempted armed robbery.

3 {6} We agree that the felony murder instruction was erroneous. As Use Note 3 to

4 UJI 14-202 NMRA provides, the jury must be instructed on the essential elements of

5 the predicate offense for felony murder. There is no dispute that attempted armed

6 robbery was the predicate offense at issue in this case and that the jury was not

7 instructed on the essential elements for that offense. As such, notwithstanding any

8 failure to object to the adequacy of the instructions that were given, we agree with

9 Defendant’s contention—and the State’s concession—that the failure to instruct the

10 jury on the essential elements of the predicate felony of attempted armed robbery

11 amounts to fundamental error requiring the reversal of Defendant’s felony murder

12 conviction and remand for a new trial on that charge. See State v. Contreras, 1995-

13 NMSC-056, ¶ 17, 120 N.M. 486, 903 P.2d 228 (recognizing that, when armed robbery

14 is the predicate felony for felony murder, proof of armed robbery is a necessary

15 element of felony murder); State v. Barber, 2004 NMSC-019, ¶ 20, 135 N.M. 621, 92

16 P.3d 633 (recognizing that the failure to instruct the jury on an essential element is

17 ordinarily fundamental error even when the defendant fails to object); see also UJI 14-

18 1621 NMRA (providing the essential elements for armed robbery); UJI 14-2801

4 1 NMRA (providing the essential elements for attempt to commit a felony). Because we

2 reverse Defendant’s felony murder conviction on this basis, we need not address

3 Defendant’s claims that the felony murder instruction also failed to include an element

4 related to his defenses of intoxication and duress.

5 Defendant’s Claim of Error By the Aggravated Burglary Instruction Is Moot

6 {7} Defendant also argues that the aggravated burglary instruction given to the jury

7 was erroneous because it too used attempted armed robbery as the predicate felony but

8 failed to set forth the essential elements of that crime. But as the State points out,

9 Defendant was implicitly acquitted of aggravated burglary when the jury convicted

10 Defendant of the lesser-included offense of burglary. We therefore agree that any

11 claimed error on this point is moot and need not be addressed further. See State v.

12 Melton, 1984-NMCA-115, ¶ 14, 102 N.M. 120, 692 P.2d 45 (noting that claims of

13 instructional error need not be addressed when related to a charge upon which the jury

14 acquitted).

15 The Instructional Errors Related to Defendant’s Burglary Conviction Require 16 Reversal

17 {8} As the parties note, “[b]urglary is a specific intent crime.” See State v. Jennings,

18 1984-NMCA-051, ¶ 14, 102 N.M. 89, 691 P.2d 882. Although the intoxication

19 instruction given to the jury for aggravated burglary provided the jury should acquit

5 1 Defendant if it found that he was too intoxicated to form the specific intent, the jury

2 was not similarly instructed with regard to the non-aggravated burglary charge. But

3 as the State concedes, the failure to instruct the jury in this regard was error because

4 burglary is also a specific intent crime for which the defense of intoxication also

5 applies.

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Related

State v. Leyba
2012 NMSC 37 (New Mexico Supreme Court, 2012)
State v. Melton
692 P.2d 45 (New Mexico Court of Appeals, 1984)
State v. Jennings
691 P.2d 882 (New Mexico Court of Appeals, 1984)
State v. Barber
2004 NMSC 019 (New Mexico Supreme Court, 2004)
State v. Almanza
2007 NMCA 073 (New Mexico Court of Appeals, 2007)
State v. Contreras
903 P.2d 228 (New Mexico Supreme Court, 1995)
State v. Atsbeha
16 P.3d 626 (Washington Supreme Court, 2001)
State v. Malloy
2001 NMCA 067 (New Mexico Court of Appeals, 2001)

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Bluebook (online)
State v. Sloan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sloan-nm-2016.