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State v. Ledesma
35,467
| N.M. Ct. App. | Sep 8, 2016
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Background

  • Defendant Melissa Ledesma was convicted of resisting, evading, or obstructing an officer, possession of marijuana, and no proof of insurance; she appealed the resisting/evading/obstructing conviction.
  • Officer activated emergency lights and later siren while attempting to stop Defendant’s vehicle; Defendant continued driving slowly for about another block and did not stop immediately when the siren was used.
  • Passengers in Defendant’s car acted nervously, moved around, appeared to hide something, and later were found with drugs and paraphernalia; opened containers and a case of beer were visible in the vehicle.
  • Drugs and drug paraphernalia were found on passengers and inside containers in the vehicle, including in Defendant’s purse.
  • The jury found Defendant guilty; she argued on appeal that the State failed to prove she knew the officer was trying to stop her and willfully refused to stop.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether evidence was sufficient to prove Defendant knew an officer was attempting to stop her and willfully refused to stop State: Circumstantial evidence (distance traveled while signaled, slow driving, passengers’ behavior, visible alcohol, contraband found) permits inference Defendant knew and willfully delayed Ledesma: She did not realize lights were directed at her until siren; even after siren she did not immediately stop and argues lack of willfulness or knowledge Affirmed — viewing evidence in the light most favorable to verdict, jury could infer knowledge and willful resistance

Key Cases Cited

  • State v. Cunningham, 128 N.M. 711, 998 P.2d 176 (explaining that courts must indulge reasonable inferences in favor of the verdict)
  • State v. Rojo, 126 N.M. 438, 971 P.2d 829 (factfinder may reject alternative versions and resolve witness credibility)
  • State v. Salas, 127 N.M. 686, 986 P.2d 482 (recognizing the jury’s role in weighing conflicting testimony)
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Case Details

Case Name: State v. Ledesma
Court Name: New Mexico Court of Appeals
Date Published: Sep 8, 2016
Docket Number: 35,467
Court Abbreviation: N.M. Ct. App.