State v. Barela, 478 P.3d 875

James Barela pleaded guilty to battery against a household member (the mother of his child) and faced sentencing after multiple prior battery convictions.
Under NMSA 1978 § 30-3-17(A), a third offense of battery against a household member is elevated to a fourth-degree felony (and a fourth or more to a third-degree felony).
At sentencing the district court (1) elevated the third battery conviction to a felony under § 30-3-17(A) and (2) added a one-year enhancement under the Habitual Offender Act, NMSA 1978 § 31-18-17, based on a prior, separate felony.
Barela appealed, arguing that a "self‑enhancing" felony (one that becomes a felony only after repeated convictions) like felony battery against a household member cannot be further enhanced under the Habitual Offender Act — relying on State v. Anaya (felony DWI).
The Court of Appeals (divided) upheld the Habitual Offender enhancement; the New Mexico Supreme Court granted certiorari and affirmed the enhancement.
The Supreme Court held that (1) the plain statutory text allows both statutes to operate simultaneously and (2) Anaya is distinguishable and limited to nonviolent DWI, so it does not bar Habitual Offender enhancements for felony battery against a household member.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Barela)	Held
Whether the Habitual Offender Act may enhance a "self‑enhancing" felony conviction for battery against a household member	Habitual Offender Act's plain text applies to any noncapital felony with a prior felony (no exclusion for household‑battery felonies)	Statute for household battery is self‑enhancing; Legislature’s silence (post‑Anaya) shows it did not intend Habitual Act to apply	Held: Yes. Statutes read harmoniously; Habitual Offender Act applies to felony household battery
Whether Anaya prohibits applying the Habitual Offender Act to felony battery against a household member	Anaya is distinguishable: felony DWI is nonviolent and had its own sentencing scheme	Anaya’s rule for self‑enhancing DWI should control and bar Habitual enhancements here	Held: Anaya is limited to nonviolent DWI with its sentencing scheme and does not control; it does not bar application here

State v. Anaya, 933 P.2d 223 (N.M. 1997) (held Habitual Offender Act did not apply to self‑enhancing felony DWI)
State v. Yparrea, 845 P.2d 1259 (N.M. Ct. App. 1992) (discussed legislative purpose of enhanced penalties to deter repeat offenders)
State v. Barela, 458 P.3d 501 (N.M. Ct. App. 2019) (Court of Appeals upheld Habitual Offender enhancement and distinguished Anaya)