State v. Madrid, A-1-CA-36322

Defendant David J. Madrid was convicted of robbery in Eddy County; he appealed raising a single issue challenging the sufficiency of the evidence.
At trial witnesses identified Madrid as a perpetrator based on voice recognition and general appearance; Madrid admitted being present at the scene but argued he was merely a bystander.
Police recovered items from Madrid’s residence and from the home of an alleged accomplice; the State relied on eyewitness ID and circumstantial evidence to connect Madrid to the robbery.
The Court of Appeals issued a proposed summary disposition upholding the conviction; Madrid filed a memorandum in opposition challenging reliability of identification and the strength of circumstantial evidence.
The court reviewed the opposition, concluded the evidence—including circumstantial evidence and witness identifications—was sufficient for a reasonable jury to find guilt beyond a reasonable doubt, and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support robbery conviction	State: eyewitness ID, defendant’s presence, and recovered items supplied ample evidence for a jury to find guilt beyond a reasonable doubt	Madrid: witness ID (voice/appearance) unreliable; his presence could be innocent/bystandership; recovered items not compelling circumstantial proof	Affirmed: viewing evidence and reasonable inferences in favor of the verdict, a rational juror could find guilt beyond a reasonable doubt

State v. Flores, 147 N.M. 542, 226 P.3d 641 (2010) (circumstantial evidence alone can constitute substantial evidence)
State v. Deaton, 74 N.M. 87, 390 P.2d 966 (1964) (substantial circumstantial evidence of participation in robbery warrants sustaining a guilty verdict)
State v. Montoya, 137 N.M. 713, 114 P.3d 393 (2005) (when jury returns guilty verdict, it has necessarily found the hypothesis of guilt more reasonable than competing hypotheses)