State v. Steele

CourtNew Mexico Court of Appeals
DecidedMarch 20, 2023
StatusUnpublished

This text of State v. Steele (State v. Steele) 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. Steele, (N.M. Ct. App. 2023).

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 COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number: _____________

3 Filing Date: March 20, 2023

4 No. A-1-CA-39869

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee,

7 v.

8 GREGG STEELE,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF TAOS COUNTY 11 Jeffrey A. Shannon, District Court Judge

12 Raúl Torrez, Attorney General 13 Laurie Blevins, Assistant Attorney General 14 Santa Fe, NM

15 for Appellee

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

19 for Appellant 1 OPINION

2 HANISEE, Judge.

3 {1} Defendant Gregg Steele appeals (1) his convictions for second degree murder,

4 contrary to NMSA 1978, Section 30-2-1(B) (1994), and tampering with evidence,

5 contrary to NMSA 1978, Section 30-22-5 (2003), as well as (2) the district court’s

6 denial of Defendant’s motion for a new trial. Defendant argues he was denied

7 effective assistance of counsel due to the district court’s adherence to applicable and

8 mandatory distancing restrictions issued by our Supreme Court in response to the

9 COVID-19 public health emergency. For the reasons that follow, we conclude

10 Defendant is unable to establish the prima facie case necessary to advance a claim

11 of ineffective assistance of counsel on direct appeal. Therefore, we affirm, but note

12 that nothing about our doing so prevents Defendant from more fully developing the

13 issue he presents in this appeal in future habeas corpus proceedings.

14 DISCUSSION

15 {2} Defendant argues the district court erred in denying his motion for a new

16 trial—and, consequently, challenges the validity of his convictions—because the

17 district court’s enforcement of public health orders, primarily the New Mexico

18 Supreme Court Order, In the Matter of Recommencing Jury Trials During the

19 COVID-19 Public Health Emergency, 20-8500-020 (N.M. May, 28, 2020) (the

20 Supreme Court Order), in which our state’s highest court set forth procedures related 1 to the recommencing of jury trials during the COVID-19 public health emergency, rendered

2 Defendant without effective assistance of counsel. See https://www.nmcourts.gov/wp-

3 content/uploads/2020/12/Order-No_-20-8500-020-Order-Recommencing-Jury-Trials-5-28-20-

4 2.pdf. Specifically, Defendant contends that one particular requirement of the

5 Supreme Court Order—namely that all individuals maintain a minimum distance of

6 six feet between one another—resulted in Defendant being unable to have privileged

7 communications with his trial counsel before and during trial. 1 Defendant states that

8 such inability to maintain privileged communications with his trial counsel

9 precluded him from electing to testify in his own defense. Defendant claims as well

10 that the district court erroneously perceived and found the Supreme Court Order to

11 incorporate a determination that the ability to maintain attorney-client

12 communications before and during proceedings is not a prerequisite for effective

13 assistance of counsel.

14 {3} Defendant’s arguments broadly center on an assertion that the district court’s

15 adherence to the Supreme Court Order resulted in Defendant receiving ineffective

16 assistance of counsel. Indeed, the alleged deficiencies by his trial counsel arose

17 solely from compliance with the district court’s enforcement of the Supreme Court

1 Defendant does not specify under what authority the social distancing restrictions were enforced at the jail. For the purposes of this discussion, we refer to the Supreme Court Order, but make no determination about whether the Supreme Court Order governed social distancing at the county jail. 2 1 Order. To the extent Defendant’s arguments challenge the propriety or legality of

2 the Supreme Court Order, we would decline to entertain such an inquiry as it should

3 instead be directed to our Supreme Court. See Alexander v. Delgado, 1973-NMSC-

4 030, ¶ 9, 84 N.M. 717, 507 P.2d 778 (“The general rule is that a court lower in rank

5 than the court which made the decision invoked as a precedent cannot deviate

6 therefrom and decide contrary to that precedent, irrespective of whether it considers

7 the rule laid down therein as correct or incorrect.” (internal quotation marks and

8 citation omitted)); see also N.M. Const. art. VI, § 3 (providing that our Supreme

9 Court is granted “superintending control over all inferior courts”); State v. Peru,

10 2022-NMCA-018, ¶ 5, 508 P.3d 907 (holding there to be no error in the district

11 court’s interpretation and enforcement of a comparable Supreme Court order related

12 to proceedings during the COVID-19 public health emergency), cert. denied (S-1-

13 SC-39205). Here, though, we perceive ourselves faced not with a question regarding

14 the legality of the Supreme Court Order itself, but rather the effects of the Supreme

15 Court Order on Defendant’s right to effective assistance of counsel.

16 {4} To raise this issue, Defendant appeals the district court’s denial of his motion

17 for a new trial, which we review for abuse of discretion. See State v. Ferguson, 1990-

18 NMCA-117, ¶ 4, 111 N.M. 191, 803 P.2d 676. Regarding Defendant’s broader

19 assertions of ineffective assistance of counsel, we reiterate that “[c]riminal

20 defendants are entitled to reasonably effective assistance of counsel under the Sixth

3 1 Amendment of the United States Constitution.” State v. Crocco, 2014-NMSC-016,

2 ¶ 12, 327 P.3d 1068 (internal quotation marks and citation omitted). “To evaluate a

3 claim of ineffective assistance of counsel, we apply the two-prong test in Strickland

4 v. Washington, 466 U.S. 668, 687 (1984).” State v. Dylan J., 2009-NMCA-027, ¶ 36,

5 145 N.M.719, 204 P.3d 44. “That test places the burden on the defendant to show

6 that his counsel’s performance was deficient and that the deficient performance

7 prejudiced his defense.” Id.; see also Crocco, 2014-NMSC-016, ¶ 14 (“[A] prima

8 facie case [of ineffective assistance of counsel] requires [the d]efendant to establish

9 both elements of ineffective assistance, attorney error and prejudice.”).

10 {5} Here, Defendant contends that the district court’s order denying Defendant’s

11 motion for a new trial erroneously concludes that confidential, in-person

12 communication between a defendant and counsel before and during trial is not

13 necessary for effective assistance. Indeed, the parties do not disagree—and neither

14 do we—that the district court’s characterization of the Supreme Court Order as

15 concluding that trial communication between a defendant and their attorney is not

16 necessary to effective representation is mistaken. Nothing about the Supreme Court

17 Order makes any such suggestion. Taking this a step further, we express concern

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Dylan J.
2009 NMCA 027 (New Mexico Court of Appeals, 2009)
State v. Ferguson
803 P.2d 676 (New Mexico Court of Appeals, 1990)
Alexander v. Delgado Ex Rel. Delgado
507 P.2d 778 (New Mexico Supreme Court, 1973)
State v. Crocco
2014 NMSC 016 (New Mexico Supreme Court, 2014)
State v. Astorga
2016 NMCA 015 (New Mexico Court of Appeals, 2015)
State v. Miera
413 P.3d 491 (New Mexico Court of Appeals, 2017)
State v. Peru
2022 NMCA 018 (New Mexico Court of Appeals, 2021)

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Bluebook (online)
State v. Steele, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-steele-nmctapp-2023.