State v. Lindsey, 2017 NMCA 48

Defendant Zachery Lindsey pled no contest to two fourth-degree felonies (shoplifting and conspiracy) in 2014 while on probation for a 2013 conditional discharge for residential burglary and larceny.
As a habitual offender under NMSA 1978, § 31-18-17(A), the district court imposed one-year habitual-offender enhancements for each count, resulting in mandatory additional time.
The district court suspended the entire sentence—including the habitual-offender enhancements—placed Lindsey on probation, and explained its findings on the record, citing his employment, restitution payments, compliance with probation, family support, and probation officer recommendation.
The State appealed, arguing the court lacked authority to suspend the mandatory enhancements absent "substantial and compelling" reasons of the restrictive kind endorsed by Michigan courts.
The Court of Appeals considered statutory interpretation of the phrase "substantial and compelling reasons" in § 31-18-17(A) and whether the district court abused its discretion in suspending the habitual-offender portion of the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of "substantial and compelling reasons" in § 31-18-17(A)	Adopt restrictive Michigan definition (only "exceptional" cases; "keenly or irresistibly" grab attention).	No attack on construction; defer to district court's discretion unless abuse.	Court rejects Michigan standard; adopts plain-meaning approach. "Substantial" means material, weighty importance; "compelling" depends on case-specific facts; not limited to "exceptional" cases.
Whether district court abused its discretion by suspending the habitual-offender enhancements	Reasons given (employment, restitution, family, probation compliance) are not sufficiently substantial/compelling under restrictive standard; suspension was improper.	District court did not abuse discretion; reasons justified suspension given probation officer recommendation and rehabilitation prospects.	No abuse of discretion. Court affirms suspension based on probation officer's testimony, restitution policy, rehabilitation goals, and statutory requirements being met.

State v. Duhon, 138 N.M. 466 (N.M. Ct. App. 2005) (statutory interpretation reviewed de novo)
State v. Davis, 134 N.M. 172 (N.M. 2003) (use plain meaning and legislative intent in statutory construction)
State v. Tsosie, 150 N.M. 754 (N.M. Ct. App. 2011) (give undefined statutory words their ordinary meaning)
State v. Gutierrez, 142 N.M. 1 (N.M. 2007) (construe coordinated adjectives to avoid surplusage)
Roy D. Mercer, LLC v. Reynolds, 292 P.3d 466 (N.M. 2013) (definition of "substantial" in professional-conduct context: material, weighty importance)
People v. Babcock, 666 N.W.2d 231 (Mich. 2003) (Michigan's restrictive definition of "substantial and compelling")
People v. Fields, 528 N.W.2d 176 (Mich. 1995) (Michigan Supreme Court's treatment of "substantial and compelling")
State v. Arrington, 115 N.M. 559 (N.M. Ct. App. 1993) (prior rule: habitual enhancement was mandatory and could not be suspended)
State v. Rojo, 126 N.M. 438 (N.M. 1999) (abuse-of-discretion standard for sentencing)