State v. Humbles, 36,143

Defendant Haven Humbles was tried by jury and convicted of one count of battery upon a peace officer and two counts of resisting, evading, or obstructing an officer.
On appeal, Humbles challenged the sufficiency of the evidence supporting those convictions.
At trial, testimony and evidence presented (summarized in the opinion) included Officer Wickens’ account that Humbles kicked him and other facts allowing the jury to infer guilt.
Defendant denied intentionally kicking Officer Wickens and argued the officer was not acting as a peace officer at the time and exceeded authority by shoving him into a police car.
The Court of Appeals reviewed the record under the standard that views evidence in the light most favorable to the verdict and draws all reasonable inferences for the prosecution.
The court rejected Humbles’ arguments, concluding there was sufficient evidence to support the convictions and affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for convictions	State argued the evidence and witness testimony allowed a reasonable juror to find elements beyond a reasonable doubt	Humbles argued evidence was insufficient to prove he intentionally kicked the officer or committed the offenses	Affirmed — viewing evidence for the prosecution, a rational juror could find guilt beyond a reasonable doubt
Whether Officer Wickens was performing duties / lawful discharge	State maintained officers were lawfully performing duties during the encounter and arrest	Humbles contended officers were not in lawful discharge of duty when the alleged conduct and arrest occurred	Affirmed — court accepted jury’s view that officers were lawfully discharging duties
Whether officer exceeded authority by shoving defendant	State implicitly contended force used was within scope of officer duties and justified	Humbles claimed Officer Wickens acted outside authority by shoving him into the police car, undermining convictions	Rejected — jury could credit prosecution evidence and reject defendant’s account; convictions stand

State v. Cunningham, 998 P.2d 176 (N.M. 2000) (standard for reviewing sufficiency of the evidence)
State v. Griffin, 866 P.2d 1156 (N.M. 1993) (appellate court will not reweigh evidence when sufficient)
State v. Rojo, 971 P.2d 829 (N.M. 1999) (jury may reject defendant’s version of facts)
State v. McGhee, 703 P.2d 877 (N.M. 1985) (weight and effect of evidence are for the trier of fact)