State v. Armijo, 2016 NMSC 21

Background

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 Supreme Court granted certiorari to resolve jurisdictional questions.
The core legal question arose from the metropolitan court’s hybrid status: it is a specialized magistrate court and is a court of record for certain criminal matters (e.g., DWI, domestic violence), so appeals to district court may be on the record rather than de novo.
Historically, New Mexico law allowed appeals from inferior courts to the district court (often de novo) and then further appellate review to the Supreme Court (and later Court of Appeals); no clear statutory carve-out had been made for district-court rulings on on-record metropolitan court appeals.
The Attorney General argued the Court of Appeals lacks jurisdiction to review district court decisions resolving on-record appeals from metropolitan court and that defendants have no right to such secondary appellate review.
The Supreme Court held that (1) the Legislature’s grant of criminal appellate jurisdiction to the Court of Appeals encompasses secondary review of district-court rulings on on-record and de novo appeals originating in metropolitan court, and (2) Section 39-3-3 provides a statutory right to appeal district-court final judgments in such matters to the Court of Appeals.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Court of Appeals has jurisdiction to review district-court decisions resolving on-record appeals from metropolitan court	The Court of Appeals lacks appellate jurisdiction over district-court rulings on on-record metropolitan-court appeals; those are not within statutory grant	The Court of Appeals has successive appellate jurisdiction over district-court decisions reviewing metropolitan-court matters	Court of Appeals has appellate jurisdiction; Section 34-5-8(A)(3) covers criminal actions including on-record reviews
Whether a party has a right to appeal a district-court decision that reviewed a metropolitan-court on the record	No statutory or constitutional right to a second record-based appeal from district court in this context	Historical practice and Section 39-3-3 grant a statutory right to appeal district-court final judgments, including those after on-record review	A party aggrieved by a district-court order in an on-record appeal has a statutory right to appeal under Section 39-3-3
Whether on-record vs. de novo appeals from metropolitan court alter appellate avenues	On-record reviews should be treated as distinct and possibly final to limit further appeals	On-record reviews are part of the same criminal action and may be reviewed on appeal like other district-court final judgments	Both on-record and de novo district-court decisions reviewing metropolitan-court matters are appealable to Court of Appeals
Whether constitutional provisions prevent further appellate review after district-court review of inferior-court matters	Article VI guarantees only a single appeal and might not guarantee appeal from appellate action of district court	Article VI’s guarantees do not bar statutory grants of further appellate review; right to appeal can be statutory	The Constitution does not prohibit statutory appellate review; Legislature’s statutes supply the right and jurisdiction

Key Cases Cited

State v. Ball, 104 N.M. 176 (discusses historical right to appeal from inferior courts to district court and further review)
State v. Wilson, 140 N.M. 218 (explains when metropolitan court appeals are de novo versus on the record)
State v. Trujillo, 126 N.M. 603 (illustrates district court on-record appellate review of metropolitan court criminal cases)
City of Portales v. Shiplett, 67 N.M. 308 (example of further appellate review after de novo district-court trial)
State v. Coats, 18 N.M. 314 (early-statehood example of appellate review from limited-jurisdiction origins)