State v. Armijo
10 N.M. 1
N.M.2016Background
- Edward Armijo was convicted of DWI in Bernalillo County Metropolitan Court; the district court affirmed on an on-record appeal, and the Court of Appeals reversed. The State sought certiorari.
- The core legal question: whether the Court of Appeals has jurisdiction to review a district court’s on-record appellate decision that reviewed a metropolitan court conviction, and whether a party has a statutory right to that secondary review.
- Historically, New Mexico law allowed de novo appeals from inferior (limited-jurisdiction) courts to district court, with further appellate review to the Supreme Court; metropolitan court was created later as a specialized magistrate court and in some instances is a court of record.
- The Legislature created the Court of Appeals and granted it broad jurisdiction over criminal appeals in NMSA 1978, § 34-5-8(A)(3); Section 39-3-3(A)(1) provides a statutory right to appeal final criminal judgments from district court to the Supreme Court or Court of Appeals.
- The metropolitan court statute (§ 34-8A-6) provides on-record review in district court for certain metropolitan criminal matters (e.g., DWI); the Legislature did not amend Section 39-3-3 to exclude district-court on-record decisions from further appellate review.
- The Supreme Court held that (1) the Court of Appeals has appellate jurisdiction to review district-court decisions on on-record appeals from metropolitan court, and (2) Section 39-3-3 supplies an aggrieved party the right to seek that review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Appeals has jurisdiction to review district-court on-record decisions reviewing metropolitan court convictions | State: Court of Appeals lacks jurisdiction over district-court on-record reviews of metropolitan court decisions; such review is within district court alone | Armijo: Court of Appeals has jurisdiction under § 34-5-8(A)(3) as successive review of criminal actions | Court: Yes. § 34-5-8(A)(3) grants the Court of Appeals successive appellate jurisdiction over criminal actions, including on-record reviews of metropolitan court cases in district court |
| Whether a party has a right to appeal a district-court on-record decision reviewing metropolitan court | State: No constitutional or statutory right to further appeal from district court acting in appellate capacity from metropolitan court | Armijo: Historical practice and § 39-3-3 confer a statutory right to appeal a final judgment of the district court (including on-record appellate decisions) to the Court of Appeals | Court: Yes. Article VI, § 27 guarantees appeal to district court; Section 39-3-3 grants a statutory right to appeal final district-court criminal judgments to the Supreme Court or Court of Appeals, including those resulting from on-record metropolitan-court review |
Key Cases Cited
- State v. Ball, 718 P.2d 686 (N.M. 1986) (discussing historical appeals from limited-jurisdiction courts and de novo practice)
- State v. Trujillo, 973 P.2d 855 (N.M. Ct. App. 1999) (illustrating district-court on-record review of metropolitan court criminal case)
- State v. Wilson, 141 P.3d 1272 (N.M. 2006) (holding entitlement to de novo trial when metropolitan court was not a court of record)
- City of Portales v. Shiplett, 355 P.2d 126 (N.M. 1960) (affirming district-court judgment after de novo appeal from justice of the peace)
- State v. Vasquez, 326 P.3d 447 (N.M. 2014) (interpreting § 34-5-8(A)(3) as granting broad jurisdiction over criminal appeals)