State v. Strauch

CourtNew Mexico Court of Appeals
DecidedMay 14, 2026
StatusUnpublished

This text of State v. Strauch (State v. Strauch) 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. Strauch, (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 Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions.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-39818

STATE OF NEW MEXICO,

Plaintiff-Appellee,

v.

JASON STRAUCH,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY Britt Baca-Miller, District Court Judge

Raúl Torrez, Attorney General Santa Fe, NM Charles J. Gutierrez, Senior Solicitor General Albuquerque, NM

for Appellee

Jason Strauch Chaparral, NM

Pro Se Appellant

MEMORANDUM OPINION

HENRY M. BOHNHOFF, Judge, retired, sitting by designation.

{1} Defendant Jason Strauch pleaded guilty to three counts of criminal sexual contact with a minor (CSCM) in the third degree (child under thirteen), in violation of NMSA 1978, Section 30-9-13(C)(1) (2003). He originally received a conditional discharge and probation for a period of five years. Defendant appeals the district court’s revocation, and denial of his motion to reconsider the revocation, of his probation and the conditional discharge, and imposition of a sentence of the balance of the maximum eighteen-year prison term.1 Defendant also claims he received ineffective assistance of counsel in connection with the revocation proceeding. We affirm.

{2} This case has a lengthy procedural history. We have reviewed the entire district and appellate court records, as well as the available recordings of the district court hearings. However, because this is a memorandum opinion and the parties are familiar with the background of the case, we reference only those facts and procedural details that we deem relevant to our analysis.

BACKGROUND

{3} Defendant was indicted in 2011 on four counts of criminal sexual contact of a minor (child under thirteen) in the second degree, in violation of Section 30-9-13(B)(1). The alleged victim was his daughter. The crimes were alleged to have been committed between 2005 and 2010. The prosecution of Defendant was held in abeyance for several years while the privileged status of Defendant’s communications with a social worker was litigated. See State v. Strauch, 2015-NMSC-009, ¶ 47, 345 P.3d 317 (holding that Defendant’s communications with his social worker were not privileged), rev’g 2014-NMCA-020, 317 P.3d 878.

{4} Following remand to the district court, Defendant agreed to plead guilty to the three lesser degree offenses between 2005 and 2007, with the previously alleged offenses to be dismissed. In a sentencing memorandum, Defendant’s counsel urged leniency, stressing that Defendant was an engineer employed at national defense research institutions, and that a conditional discharge, see NMSA 1978, § 31-20-13 (1994), and probation would permit him to continue making valuable contributions to society. At a July 2016 hearing, the district court accepted the plea agreement, entered an order of conditional discharge as to the crimes to which Defendant pleaded guilty, and placed him on probation for five years.

Defendant’s First Three Probation Violations

{5} Between August 2016 and March 2017, the State filed three motions, along with probation officers’ supporting reports, charging Defendant with violating the terms of his probation; each time, the State moved to revoke Defendant’s probation. On each occasion, the district court ultimately exercised leniency and continued Defendant’s conditional discharge and probation terms.

{6} The first report alleged that Defendant had not been truthful with his probation officers, in particular, that in early August 2016, Defendant had lied to the officer about his whereabouts and his possession of a smart phone. At an early September 2016 hearing, Defendant admitted the allegation and apologized for his error in judgment. The district court revoked but then reinstated his probation.

1The maximum sentence for each of the CSCM crimes to which Defendant pleaded is six years. See NMSA 1978, § 31-18-15(C) (2016, amended 2025). {7} The second report alleged that in late September 2016, without first obtaining permission from his probation officer, Defendant had visited a public park where children could be expected to gather. At a November 2016 hearing, after Defendant admitted to the violation, the district court again revoked but then reinstated his probation. However, the court accepted the parties’ joint proposal that, prior to reinstating probation, Defendant would serve sixty days in jail. The court warned Defendant that there was no room for another mistake.

{8} The third report alleged that Defendant had consumed a beer in February 2017. At an initial hearing, Defendant admitted the violation and the district court accepted the admission. At the sentencing hearing in late April 2017, a psychologist who had recently evaluated Defendant testified that she had diagnosed him with Autism Spectrum Disorder (ASD), formerly known as Asperger’s Syndrome, and suggested his probation violations were attributable to the previously undiagnosed condition. At the conclusion of the hearing, after stating that it did not believe Defendant could handle probation, the court revoked Defendant’s probation and sentenced him to six years in prison.

{9} Defendant’s counsel filed a motion to reconsider the sentence pursuant to Rule 5-801 NMRA. The district court held multiple hearings between December 2017 and October 2018. At several of these hearings, the court heard lengthy testimony not only from the previously retained psychologist but also from a neuropsychiatrist. Both witnesses further addressed the causal connection between Defendant’s ASD and his propensity to violate his probation terms, but opined that, with therapy, he should learn to comply with the rules. However, the neuropsychiatrist testified that if, following such therapy, Defendant continued to willfully violate his probation conditions, there would be no reason to continue with probation.

{10} Following these hearings, the district court reinstated the original conditional discharge and reinstated Defendant’s probation for five years. The court stressed that it usually did not give sex offenders even a second chance, but that it was attempting to accommodate Defendant’s ASD. The court emphasized that this was its fourth attempt to work with Defendant but there would not be a fifth, and Defendant needed to understand that he had to comply with even minor conditions. Defendant assured the court that he understood that there was “no wiggle room.”

Defendant’s Fourth Probation Violation and Revocation of His Probation

{11} In August 2019, the State filed a fourth motion to revoke Defendant’s probation, based on a new report alleging further violations of his probation conditions. The primary allegation was that beginning in late 2018 and continuing into early 2019, Defendant had phoned, texted, and met with a former girlfriend who had a history of driving while intoxicated and with whom his probation officer had instructed him not to associate. {12} At the beginning of the October 3, 2019 hearing on the motion, defense counsel stated that Defendant would admit to violating this “association” condition. Following questioning, the district court accepted the admission.

{13} Defendant’s neuropsychiatrist addressed the district court. He testified that Defendant had been making progress with therapy but that more was needed.

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Cite This Page — Counsel Stack

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