State v. Maples, 300 P.3d 749

Maples was convicted of voluntary manslaughter, false imprisonment, tampering with evidence, and conspiracy to tamper with evidence.
The district court excluded testimony by police officers about Victim’s prior acts while under methamphetamine, offered to show Victim’s behavior and fear, as impermissible character evidence.
Defense proffered evidence described Victim’s strong resistance and unusual behavior in encounters with officers.
The State moved in limine to exclude the officers’ testimony; the court ruled the evidence inadmissible under 11-404(A) and 11-405, and the jury heard no such testimony.
On appeal, Maples contends the exclusion violated his right to present a complete defense and affected the verdict.
The Court reverses and remands for a new trial based on the erroneous exclusion of the officers’ testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Victim’s prior acts as non-character evidence	Maples argues 11-404(B) permits non-character purposes.	Maples contends the testimony is probative to corroborate his self-defense claim.	Abuse of discretion; testimony admissible under 11-404(B) for corroboration.
Whether Armendariz limits admissibility of specific prior acts	State/ court relied on Armendariz to exclude specific acts.	Armendariz limits use of specific prior acts in self-defense contexts.	Armendariz does not bar admissibility here; proper standard is 11-404(B) with 11-403 balancing.
Whether the officers’ testimony was probative and properly tailored	Testimony corroborates Maples’ version and Victim’s behavior on meth.	Testimony risks improper propensity inference.	Yes, admissible for corroboration; tailor testimony on remand.
Sufficiency of the evidence to convict for voluntary manslaughter	Evidence showed Victim killed by choking while restrained.	Force used was excessive or not proven to meet manslaughter elements.	There was sufficient evidence under substantial-evidence standard; retrial not barred.
Remand for new trial following evidentiary ruling	Reversal on evidentiary grounds requires new trial.	N/A	Remand for a new trial consistent with admissibility rulings.

Armendariz v. State, 140 N.M. 182, 141 P.3d 526 (2006-NMSC-036) (limitations on specific-acts evidence in self-defense)
State v. Baca, 114 N.M. 668, 845 P.2d 762 (1992) (methods of proving victim’s pertinent trait; exceptions under 11-405)
State v. Gallegos, 141 N.M. 185, 152 P.3d 828 (2007-NMSC-007) (non-charactevidence purposes under 11-404(B) stated; balancing under 11-403)
State v. Lamure, 115 N.M. 61, 846 P.2d 1070 (Ct. App. 1992) (distinguishing general propensity from particular acts)
State v. Swavola, 114 N.M. 472, 840 P.2d 1238 (Ct. App. 1992) (recognizes non-character purpose for acts evidence)