State v. Stevens

CourtNew Mexico Court of Appeals
DecidedMay 27, 2025
StatusUnpublished

This text of State v. Stevens (State v. Stevens) 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. Stevens, (N.M. Ct. App. 2025).

Opinion

The slip opinion is the first version of an opinion released by the Clerk of the Court of Appeals. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Clerk of the Court 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: May 27, 2025

4 No. A-1-CA-40660

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellant,

7 v.

8 JACOBY STEVENS,

9 Defendant-Appellee.

10 APPEAL FROM THE DISTRICT COURT OF COLFAX COUNTY 11 Melissa A. Kennelly, District Court Judge

12 Raúl Torrez, Attorney General 13 Santa Fe, NM 14 Walter Hart, Assistant Attorney General 15 Erica E. Schiff, Assistant Attorney General 16 Albuquerque, NM

17 for Appellant

18 Bennett J. Baur, Chief Public Defender 19 Mallory E. Harwood, Assistant Appellate Defender 20 Santa Fe, NM

21 for Appellee 1 OPINION

2 YOHALEM, Judge.

3 {1} In this appeal, the State asks this Court to determine whether it has an

4 obligation under Rule 11-707(C) and (D) NMRA to collect and produce the raw data

5 from an audio or video recording of a polygraph examination administered by law

6 enforcement as part of its investigation of a crime, when the State does not seek to

7 offer the results into evidence at trial. We conclude that when a polygraph

8 examination is not offered into evidence at trial, Rule 11-707(C) and (D) does not

9 require the collection and production to the opposing party of the polygraph

10 recording and physical polygraph data in order to admit law enforcement’s post-

11 examination interrogation of the defendant into evidence. We therefore reverse the

12 district court’s order sanctioning the State and remand for trial consistent with this

13 opinion.

14 BACKGROUND 1

15 {2} On February 20, 2020, local law enforcement was dispatched to the medical

16 center in Raton, New Mexico, to investigate a report of child abuse. The child that

17 medical staff believed had been abused was Defendant Jacoby Stevens’ one-year-

18 old stepson (Child). Child was not expected to survive serious injuries that included

1 We draw the facts from law enforcement’s affidavit for Defendant’s arrest warrant, Defendant’s predetention hearing, and Defendant’s motions to exclude the polygraph examination and the responses and hearings on those motions. 1 a skull fracture and brain bleed. Defendant was questioned by a Raton police officer

2 at the medical center about Child’s injuries. Defendant admitted that he had been

3 taking care of Child alone on February 20, 2020, while Child’s mother was at work.

4 When asked what could have caused Child’s injuries, Defendant stated that the only

5 potential cause was a fall from a rocking horse a few days before; Defendant reported

6 that Child appeared to be fine on the two intervening days. Defendant stated that he

7 had not noticed anything wrong with Child until late in the afternoon on February

8 20, 2020, when he noticed that Child was not breathing, and when he picked him up,

9 Child was limp. When the officer asked Defendant if there were any other possible

10 reasons for Child’s injuries besides the fall from the rocking horse, Defendant stated

11 he could not think of anything else. Child was transported to the University of New

12 Mexico Hospital in Albuquerque, New Mexico, for treatment, and died there on

13 February 22, 2020.

14 {3} On March 5, 2020, Defendant agreed to allow law enforcement to conduct a

15 polygraph examination as part of the investigation into Child’s death. For reasons

16 not addressed by evidence in the record, the Raton Police Department asked Federal

17 Bureau of Investigation (FBI) Agent Marcus McCaskill, who was qualified as a

18 polygrapher, to administer the examination. Although he was not in custody,

19 Defendant was Mirandized prior to the examination. Agent McCaskill informed

20 Defendant that the polygraph examination would not be recorded. The purpose of

2 1 the examination was to determine whether Defendant’s statement to Raton police—

2 that the sole cause of Child’s injuries was the fall from a rocking horse—was

3 truthful. Defendant agreed to participate because he hoped to be ruled out as a

4 suspect in Child’s death. According to Agent McCaskill, the examination showed

5 that Defendant was not being truthful.

6 {4} After the polygraph examination concluded, Agent McCaskill questioned

7 Defendant about his interaction with Child on the afternoon of February 20, 2020,

8 the day Defendant brought Child to the hospital and the day doctors believed Child’s

9 injuries occurred. This interrogation was recorded. Defendant was told by Agent

10 McCaskill (truthfully) that the doctors who treated Child’s injuries did not believe

11 such severe injuries could have been caused by falling off a rocking horse. Defendant

12 responded by describing for the first time an incident that he claimed happened when

13 Child was finishing lunch on February 20, 2020. Defendant told Agent McCaskill

14 that Child had gotten tangled in the buckles on his high chair, that he had tried to

15 disentangle Child, but Child slipped out of his hands and fell to the floor.

16 {5} When told by Agent McCaskill that Child’s doctors believed, based on his

17 injuries, that Child must have been shaken, Defendant first told Agent McCaskill

18 that he had playfully tossed Child in the air, and then explained that he also shook

19 Child when he picked Child up from his crib and found him not breathing. When

20 Defendant was told that Child’s doctors believed that Child’s skull fracture had been

3 1 caused by Child being forcefully hit on the head with a blunt instrument, Defendant

2 said that he heard a “thump” as he was rushing to get Child to the hospital, and that

3 Child may have hit his head on the door frame. Defendant put this new description

4 of the events of February 20, 2020, into a handwritten statement, and signed and

5 dated that statement, as did Agent McCaskill. The State charged Defendant with

6 intentional child abuse resulting in death, contrary to NMSA 1978, Section 30-6-

7 1(H) (2009).

8 {6} Following Defendant’s arrest, the State informally produced to the defense on

9 March 11, 2020, before Defendant’s pretrial detention hearing, both a copy of the

10 audio recording of the post-examination interview of Defendant and Defendant’s

11 written statement, and, again, produced additional copies formally in a discovery

12 package on April 6, 2020. The State gave the defense a copy of Agent McCaskill’s

13 polygraph examination report on March 18, 2020, stating Agent McCaskill’s expert

14 opinion as a polygrapher that Defendant was not being truthful in his responses to

15 the relevant questions asked during the polygraph examination.

16 {7} No audio or video recording of the polygraph examination had been made,

17 pursuant to FBI policy, so no recording could be produced. The charts and other raw

18 data were in the possession of the FBI, and FBI policy prohibited release of a copy

19 for national security reasons. Therefore, the raw data also was not produced by the

20 State to Defendant.

4 1 {8} Although the State initially included Agent McCaskill on its witness list as a

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State v. Stevens, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-stevens-nmctapp-2025.