State v. Chavez-Crispin
Background
- Defendant Aurelio Chavez Crispin was convicted by a jury of two counts of first-degree criminal sexual penetration of a minor.
- On appeal, the defendant challenged (1) the district court's evidentiary decision to allow the victim's testimony about receiving a pill she later believed was "plan B" after unprotected sex, and (2) the denial of his motion for a new trial based on newly discovered evidence.
- Defendant argued the pill testimony was more prejudicial than probative and thus should have been excluded under Rule 11-403 NMRA.
- The defendant also sought a new trial, arguing that evidence relating to the victim's involvement in an investigation of another case provided a motive for her to fabricate allegations against him.
- The district court found the new evidence would be used only to impeach the victim's credibility, not as substantive evidence.
- The Court of Appeals affirmed the district court’s decisions on all issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of victim’s "plan B" pill testimony | Testimony corroborates victim's account and is probative of defendant's guilt | Testimony is unfairly prejudicial and cumulative; probative value outweighed by prejudice | Admission was not an abuse of discretion; probative value outweighed any prejudice |
| Denial of motion for new trial on newly discovered evidence | Evidence is merely impeaching and not substantive | Evidence would support motive for fabrication; relevant to guilt or innocence | Motion properly denied; evidence was only impeaching, did not warrant new trial |
Key Cases Cited
- State v. Bailey, 386 P.3d 1007 (N.M. 2017) (standard for evidentiary admission under Rule 11-403: abuse of discretion)
- State v. Garcia, 125 P.3d 638 (N.M. 2005) (standards for motions for new trial based on newly discovered evidence)
- State v. Desnoyers, 55 P.3d 968 (N.M. 2002) (motions for new trial on new evidence are generally discouraged)
- State v. Roybal, 273 P. 919 (N.M. 1928) (scope and nature of impeachment evidence)
- State v. Layne, 189 P.3d 707 (N.M. Ct. App. 2008) (on the purpose of impeachment evidence)