State v. Begay, 390 P.3d 168

Trevor Begay pleaded no contest to a petty misdemeanor battery in magistrate court; the court suspended most of a 182-day sentence and imposed supervised probation.
Begay failed to complete required conditions (life-skills class and community service); he did not appear at a probation hearing and the magistrate court issued a bench warrant on September 25, 2012.
Begay’s original probationary term would have expired on December 27, 2012, while the bench warrant remained outstanding.
Begay was arrested February 11, 2013, admitted violating probation, and on March 14, 2013 the magistrate court revoked probation and imposed 171 days, suspending part and awarding jail credit.
The district court (de novo review) upheld the revocation; the Court of Appeals reversed, holding the magistrate court lacked authority to toll the probation under the statute and that Begay’s probation expired on December 27, 2012. The Supreme Court granted certiorari.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Begay)	Held
Whether a magistrate court had jurisdiction to revoke probation when the probationary term expired while the defendant was subject to an outstanding bench warrant	Section 31-20-8 should not be read to bar revocation where the defendant absconded; revocation is valid because defendant’s fugitive status prevented the running of the term	Section 31-20-8 relieves defendant of obligations when the suspension period "expires without revocation," and Section 31-21-15(C) (pre-2016) did not authorize tolling by magistrate courts, so magistrate lost jurisdiction on expiration	Held for State: magistrate had jurisdiction to revoke; Section 31-20-8 does not deprive the court of jurisdiction where the defendant absconded and a warrant was outstanding

State v. Ordunez, 283 P.3d 282 (N.M. 2012) (Section 31-20-8 bars revocation when revocation occurs after expiration absent defendant-caused delay)
State v. Lara, 9 P.3d 74 (N.M. Ct. App. 2000) (trial court lacked jurisdiction where order entered after probation expired and defendant was not responsible for delay)
State v. Travarez, 657 P.2d 636 (N.M. Ct. App. 1983) (interpretation of probation-expiration effect on revocation power)
Cannon v. State, 457 So.2d 1177 (La. 1984) (probationary period ceases to run when defendant is a fugitive; running may be suspended by defendant’s flight)
State v. Maestas, 149 P.3d 933 (N.M. 2007) (statutory construction requires avoiding absurd results; depart from plain meaning when legislature could not have intended absurdity)