State v. Veleta

CourtNew Mexico Supreme Court
DecidedAugust 14, 2023
StatusUnpublished

This text of State v. Veleta (State v. Veleta) 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. Veleta, (N.M. 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 SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number: __________________

3 Filing Date: August 14, 2023

4 NO. S-1-SC-38169

5 STATE OF NEW MEXICO,

6 Plaintiff-Appellee, 7 v.

8 JAIME VELETA,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY 11 Cindy Leos, District Judge

12 Harrison & Hart, LLC 13 Nicholas T. Hart 14 Carter B. Harrison IV 15 Ramon A. Soto 16 Albuquerque, NM

17 for Appellant

18 Hector H. Balderas, Attorney General 19 Walter M. Hart, III, Assistant Attorney General 20 Santa Fe, NM

21 for Appellee 1 OPINION

2 VARGAS, Justice.

3 {1} This case comes to the Court on direct appeal pursuant to Rule 12-102(A)(1)

4 NMRA. Defendant Jaime Veleta appeals his conviction for willful and deliberate

5 first-degree murder, claiming the district court made several evidentiary errors,

6 improperly instructed the jury, permitted the entry of inconsistent verdicts, and

7 violated his double jeopardy rights by allowing the inconsistent verdicts to stand.

8 Defendant presents a novel argument that a verdict convicting him of first-degree

9 murder but acquitting him of the lesser-included offenses of second-degree murder

10 and voluntary manslaughter is legally inconsistent. We take this opportunity to

11 address New Mexico law on inconsistent verdicts to explain that only inconsistent

12 convictions and not inconsistent verdicts are reviewed. When the evidence is

13 sufficient to support the verdict of conviction, 1 we will not speculate as to why the

14 jury acquitted a defendant of other charges. To examine the verdict of acquittal

15 requires that either we rule based on pure speculation or we inquire into the jury’s

16 deliberations, neither of which we are willing to do.

1 This opinion uses verdict of conviction to refer to the jury’s guilty verdict on a charge, giving rise to the district court’s conviction on that charge. Similarly, we use verdict of acquittal to refer to the jury’s not guilty verdict on a charge, giving rise to the district court’s acquittal on that charge. 1 I. BACKGROUND

2 {2} In January 2008, Defendant and four others went to the house of Danny Baca

3 (Victim) to confront him about a missing car that contained drugs. After discovering

4 that the car had been stripped and the drugs were missing, Defendant and the other

5 men took Victim from his home. Eventually, Defendant and two of his accomplices,

6 Jose and Mario Talavera, drove Victim out to the mesa where Defendant shot Victim

7 at least eighteen times, killing him, before lighting his body on fire. Shortly after

8 killing Victim, Jose and Mario took Defendant to the bus depot where Defendant

9 boarded a bus to Mexico. Defendant was charged with the murder of Victim in 2011

10 but was not extradited to New Mexico until 2018.

11 {3} At trial, Jose and another of Defendants’ accomplices, Gerardo Nuñez,

12 testified at length about Defendant’s involvement in Victim’s murder. At the

13 conclusion of the trial, the jury entered verdict forms convicting Defendant of willful

14 and deliberate first-degree murder, felony murder in the first-degree, kidnapping,

15 conspiracy, and tampering with evidence. The jury also entered verdict forms

16 acquitting Defendant of second-degree murder and voluntary manslaughter. The

17 district court vacated his felony murder conviction, merging it into his conviction

18 for willful and deliberate first-degree murder, and sentenced him to life in prison.

19 Defendant appealed directly to this Court. N.M. Const. art. VI, § 2 (“Appeals from

2 1 a judgment of the district court imposing a sentence of death or life imprisonment

2 shall be taken directly to the supreme court.”); Rule 12-102(A)(1).

3 II. DISCUSSION

4 {4} Defendant asks this Court to vacate his convictions, alleging the district court

5 (1) abused its discretion when it permitted the introduction of evidence that

6 Defendant fled the country following the murder of Victim, (2) erred when it

7 improperly limited Defendant’s cross-examination of two witnesses, violating his

8 right to confrontation, (3) erred when it improperly instructed the jury with regard

9 to the stepdown instruction and the lesser-included offenses of first-degree murder

10 leading to a legally inconsistent verdict, and (4) erred when it entered his conviction

11 for first-degree murder despite his implied acquittal. Defendant further claims that

12 he is entitled to the reversal of his convictions and requests that the case be remanded

13 to the district court for a new trial. He argues, however, that retrial for first-degree

14 murder, second-degree murder, or voluntary manslaughter is barred by double

15 jeopardy. Finally, Defendant claims cumulative error. Concluding that there was no

16 error, we affirm the district court.

17 A. Claims of Evidentiary Error

18 {5} Defendant claims that the district court made evidentiary errors requiring

19 reversal by (1) admitting evidence of Defendant’s flight from New Mexico to

3 1 demonstrate consciousness of guilt, (2) denying Defendant the opportunity to cross-

2 examine Gerardo about his uncle’s federal drug charges, and (3) limiting

3 Defendant’s cross-examination of Jose about his cooperation with law enforcement.

4 “The admission or exclusion of evidence is within the discretion of the trial court.

5 On appeal, the trial court’s decision is reviewed for abuse of discretion.” State v.

6 Hughey, 2007-NMSC-036, ¶ 9, 142 N.M. 83, 163 P.3d 470. “An abuse of discretion

7 arises when the evidentiary ruling is clearly contrary to logic” or when the district

8 court “misapplies or misapprehends the law.” State v. Pacheco, 2008-NMCA-131,

9 ¶ 34, 145 N.M. 40, 193 P.3d 587 (internal quotation marks and citation omitted). For

10 the reasons that follow, we conclude that the district court did not abuse its discretion

11 in any of the evidentiary rulings challenged by Defendant.

12 1. Flight evidence as consciousness of guilt

13 {6} Defendant contends the district court abused its discretion by admitting

14 evidence of his travel to Mexico immediately after Victim was killed as evidence of

15 consciousness of guilt because the State failed to show that he knew he was being

16 pursued by law enforcement at the time he left for Mexico. The State contends that

17 knowledge of law enforcement pursuit is not a prerequisite for admission of flight

18 evidence and asserts that “it is the contemporaneity of the occurrence of the crime

19 and the flight that creates the reasonable inference of consciousness of guilt.”

4 1 {7} We agree with the State. “Flight evidence is admissible because [it] tends to

2 show consciousness of guilt.” State v. Trujillo, 1979-NMCA-055, ¶ 4, 93 N.M. 728,

3 605 P.2d 236 (internal quotation marks and citation omitted). “[T]he prosecution is

4 not required to establish the reason for a defendant’s flight,” and “a defendant’s

5 knowledge that he was being pursued is not a predicate to the admission of flight

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Dunn v. United States
284 U.S. 390 (Supreme Court, 1932)
In Re WINSHIP
397 U.S. 358 (Supreme Court, 1970)
Davis v. Alaska
415 U.S. 308 (Supreme Court, 1974)
United States v. Powell
469 U.S. 57 (Supreme Court, 1984)
Delaware v. Van Arsdall
475 U.S. 673 (Supreme Court, 1986)
Schiffer v. United Grocers, Inc.
989 P.2d 10 (Oregon Supreme Court, 1999)
Beattie v. State
924 N.E.2d 643 (Indiana Supreme Court, 2010)
State v. Montoya
2013 NMSC 020 (New Mexico Supreme Court, 2013)
State v. Cabezuela
2011 NMSC 41 (New Mexico Supreme Court, 2011)
State v. Gallegos
2011 NMSC 027 (New Mexico Supreme Court, 2011)
State v. Sandoval
2011 NMSC 022 (New Mexico Supreme Court, 2011)
State v. Swick
2012 NMSC 18 (New Mexico Supreme Court, 2012)
State v. Casillas
2009 NMCA 34 (New Mexico Court of Appeals, 2009)
State v. Romero
2009 NMCA 12 (New Mexico Court of Appeals, 2008)
Alba v. Hayden
2010 NMCA 037 (New Mexico Court of Appeals, 2010)
State v. Parish
878 P.2d 988 (New Mexico Supreme Court, 1994)
State v. Sanders
872 P.2d 870 (New Mexico Supreme Court, 1994)
State v. Meadors
908 P.2d 731 (New Mexico Supreme Court, 1995)
State v. Leyba
453 P.2d 211 (New Mexico Court of Appeals, 1969)
State v. Gonzales
1999 NMSC 033 (New Mexico Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Veleta, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-veleta-nm-2023.