State v. Garcia-Larondo, A-1-CA-36482

Defendant Ramiro Garcia-Larondo appealed the district court's revocation of his probation following consolidated plea/sentencing of two originally separate cases.
The revocation hearing record (case D-202-CR-2014-04505) found multiple probation violations after an evidentiary hearing.
The district court determined Defendant willfully: concealed his identity, failed to report, failed to notify of address changes, refused required residence visits, and failed to comply with drug testing and hotline requirements (including failing to provide urine samples).
The State bore the burden to prove the probation violations with reasonable certainty and that they were willful.
Defendant argued in his memorandum in opposition that the record does not explain why he violated probation and did not present evidence excusing noncompliance.
The Court of Appeals issued a calendar notice proposing affirmance; after Defendant’s memorandum in opposition, the Court affirmed the revocation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to revoke probation	State: Presented proof of multiple probation violations and willfulness	Garcia-Larondo: Record lacks explanation for violations; no evidence excusing noncompliance	Affirmed: Court found sufficient evidence of willful violations; Defendant failed to show nonwillfulness
Who bears burden to excuse violations	State: Once breach proved, defendant must show nonwillfulness	Garcia-Larondo: Asserted no explanation in record (did not present evidence)	Affirmed: Defendant had burden to present evidence that violations were beyond his control and did not do so

No key authorities with official reporter citations appear in the opinion; the opinion relies on New Mexico Court of Appeals decisions cited by case name and opinion number only (e.g., State v. Leon; In re Bruno R.; State v. Martinez; State v. Parsons; State v. Mondragon).