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