State v. Chavez, 35,240

Defendant convicted of trafficking methamphetamine under NMSA 1978, § 30-31-20; appeal followed to the Court of Appeals.
Defendant moved in limine to exclude evidence of his involvement in a prior uncharged drug transaction; the district court denied the motion, ruling prior-transaction evidence would be admissible to impeach if Defendant testified.
Defendant did not testify at trial; he contends the limine ruling chilled his testimony and prevented him from presenting a subjective-entrapment defense.
Defendant also moved to compel disclosure of a confidential informant’s identity; the district court conducted an in camera review of police materials and declined to order disclosure.
The court of appeals reviewed both rulings for abuse of discretion and considered whether prior-transaction evidence could be relevant to entrapment/predisposition and whether the informant could provide testimony necessary or helpful to Defendant’s defense.
The Court of Appeals affirmed the conviction, finding no abuse of discretion in either the denial of the motion in limine or the denial of disclosure of the informant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior uncharged drug transaction evidence	State: Such evidence may be admissible for non-character purposes (knowledge, identity, predisposition) if relevant to testimony	Defendant: Ruling allowed impeachment and therefore chilled his testimony, preventing entrapment defense	Affirmed — district court did not abuse discretion; prior-transaction evidence could be relevant to subjective entrapment and impeachment is permissible if Defendant testifies
Disclosure of confidential informant identity	State: Privilege to refuse disclosure; in camera review showed informant had no relevant/helpful testimony	Defendant: Informant’s identity was necessary to prove entrapment and would have provided testimony that aided his defense	Affirmed — district court did not abuse discretion; in camera review supported nondisclosure because informant was not a witness to the charged transaction and could not be shown to be necessary/helpful

State v. Garnenez, 344 P.3d 1054 (N.M. Ct. App. 2015) (standard of review for evidentiary rulings)
State v. Moreland, 185 P.3d 363 (N.M. 2008) (abuse-of-discretion standard explained)
State v. Attaway, 835 P.2d 81 (N.M. Ct. App. 1992) (prior uncharged drug dealings relevant to knowledge/identification of drugs)
State v. Dartez, 952 P.2d 450 (N.M. Ct. App. 1998) (predisposition evidence relevant to subjective entrapment)
State v. Godoy, 284 P.3d 410 (N.M. Ct. App. 2012) (issues unsupported by authority may be deemed waived)
State v. Rojo, 971 P.2d 829 (N.M. 1999) (abuse-of-discretion review for informant-identity rulings)
State v. Jim, 765 P.2d 195 (N.M. Ct. App. 1988) (defendant bears burden to provide record sufficient for appellate review)
State v. Lovato, 868 P.2d 1293 (N.M. Ct. App. 1993) (denial of disclosure proper where defendant fails to show how informant’s testimony would aid entrapment defense)
State v. Chandler, 895 P.2d 249 (N.M. Ct. App. 1995) (identity of informant not relevant when informant did not witness charged conduct)