State v. Lerma, 35,169

Defendant Jesus Lerma was convicted by a jury of aggravated assault on a household member with a deadly weapon, false imprisonment, and battery on a household member.
The State prosecuted and the jury returned guilty verdicts; the district court entered judgment and sentence.
On appeal Lerma challenged the sufficiency of the evidence supporting his convictions.
The Court of Appeals issued a proposed summary affirmance; the public defender filed a memorandum in opposition addressing the sufficiency issue.
The appellate court reviewed the record, viewed the evidence in the light most favorable to the verdict, and applied the standard deferring to the jury on credibility and conflict resolution.
The Court concluded substantial direct or circumstantial evidence supported each element of the offenses and affirmed the convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support convictions	Evidence presented at trial supported each element; jury properly resolved credibility	Victim's testimony was untruthful; evidence insufficient to convict	Affirmed — substantial evidence exists; appellate review defers to jury credibility findings

State v. Garcia, 246 P.3d 1057 (N.M. 2011) (appellate review of sufficiency defers to jury credibility determinations)
State v. Montoya, 345 P.3d 1056 (N.M. 2015) (sufficiency test requires substantial direct or circumstantial evidence supporting every element)
State v. Cunningham, 998 P.2d 176 (N.M. 2000) (view evidence in the light most favorable to the guilty verdict; indulge reasonable inferences)
State v. Salas, 986 P.2d 482 (N.M. Ct. App. 1999) (fact-finder resolves conflicts in witness testimony)
State v. Rojo, 971 P.2d 829 (N.M. 1998) (disregard evidence and inferences that support a different result)