State v. Gonzalez
36,247
N.M. Ct. App.Jul 28, 2017Background
- Defendant Ray Jeff Gonzales was convicted in San Juan County for trafficking a controlled substance under NMSA 1978, § 30-31-20.
- At trial, Agent Nickerson testified that he personally purchased methamphetamine from Gonzales (undercover buy).
- The prosecution relied on the undercover purchase plus other corroborating evidence presented at trial.
- Gonzales appealed, challenging the sufficiency of the evidence supporting the trafficking conviction.
- The Court of Appeals issued a proposed summary disposition to affirm; Gonzales filed a memorandum in opposition but raised no new persuasive legal or factual points.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support trafficking conviction | Evidence (undercover officer’s purchase and corroborating facts) is sufficient to prove guilt beyond a reasonable doubt | All evidence was circumstantial; gaps exist concerning the CI, a man who approached the vehicle, and a circling vehicle, so evidence is insufficient | Affirmed — direct testimony of the undercover purchase plus corroborating evidence sufficed; defendant’s challenges did not overcome the showing of guilt |
Key Cases Cited
- Rael v. State, 127 N.M. 347, 981 P.2d 280 (1999) (upholding trafficking convictions where undercover officer testified to purchasing narcotics)
- State v. Chandler, 119 N.M. 727, 895 P.2d 249 (1995) (circumstantial evidence can support conviction when it permits reasonable inferences of guilt)
- State v. Mondragon, 107 N.M. 421, 759 P.2d 1003 (1988) (party responding to a summary calendar notice must identify specific errors of law or fact)
