State v. Happy, A-1-CA-36201

Defendant Emerson Happy was convicted by a jury of one count of battery upon a peace officer under NMSA 1978, § 30-22-24 after a trial in San Juan County district court.
Incident occurred during booking at the San Juan County Detention Center where Officer Sean Eckstein, in uniform, was processing Defendant’s intake.
Defendant became agitated; officers moved him to a small enclosed booking area (“cage”) and attempted to seat and handcuff him.
Testimony established Defendant stood abruptly, shoulder-checked Officer Eckstein, then grabbed him around the waist and lifted him; Eckstein punched Defendant twice to free himself and other officers separated them.
Video evidence was admitted but reportedly showed mainly backs of individuals; jury found Defendant guilty and the district court entered judgment and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Defendant’s conduct threatened officer safety or meaningfully challenged authority under § 30-22-24	State argued testimony (shoulder-check, waist grab, lifting officer, need for punches and other officers) supported a finding of an actual threat or meaningful challenge	Happy argued the evidence did not show an actual threat to Officer Eckstein’s safety or a meaningful challenge to his authority	Court affirmed: viewing evidence in prosecution’s favor, a rational jury could find beyond reasonable doubt that Defendant’s actions met the statutory element requiring injury or conduct threatening safety or authority

State v. Cunningham, 128 N.M. 711, 998 P.2d 176 (N.M. 2000) (standard for reviewing sufficiency of the evidence)
State v. Padilla, 123 N.M. 216, 937 P.2d 492 (N.M. 1997) (§ 30-22-24 requires proof of injury or conduct that threatens an officer’s safety or meaningfully challenges authority)
Hennessy v. Duryea, 124 N.M. 754, 955 P.2d 683 (N.M. Ct. App. 1998) (burden on appellee to point out errors in summary calendar proceedings)