State v. Roberts, A-1-CA-36382

Defendant Jeremy W. Roberts was convicted by a jury of false imprisonment (NMSA 1978, § 30-4-3) and battery against a household member (NMSA 1978, § 30-3-15).
The Court of Appeals issued a proposed disposition to summarily affirm; Defendant filed a memorandum in opposition but the panel remained unpersuaded.
The central factual dispute concerned the victim’s account that she was beaten and detained by Defendant; Defendant offered a different version of events.
The appeal challenges the sufficiency of the evidence supporting the convictions and disputes the victim’s credibility.
The appellate court reviewed the evidence in the light most favorable to the prosecution, noting that intent may be inferred from conduct and circumstances.
The court applied the presumption of correctness to the district court’s rulings and placed the burden on Defendant to clearly demonstrate error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support convictions	State: Evidence (including victim’s testimony and circumstantial evidence) was sufficient	Roberts: Insufficient evidence; victim not credible; alternative version of events	Affirmed: Evidence sufficient; credibility for jury; intent may be inferred from conduct

State v. Slade, 331 P.3d 930 (N.M. Ct. App. 2014) (standard for reviewing sufficiency of evidence)
State v. Flores, 226 P.3d 641 (N.M. 2010) (circumstantial evidence and inference of intent)
State v. Michael S., 904 P.2d 595 (N.M. Ct. App. 1995) (intent can be inferred from conduct and circumstances)
State v. Aragon, 981 P.2d 1211 (N.M. Ct. App. 1999) (presumption of correctness for district court rulings)
Farmers, Inc. v. Dal Mach. & Fabricating, Inc., 800 P.2d 1063 (N.M. 1990) (appellant’s burden to clearly demonstrate error)
State v. Salas, 986 P.2d 482 (N.M. Ct. App. 1999) (credibility determinations are for the jury)
State v. Griffin, 866 P.2d 1156 (N.M. 1993) (appellate court will not reweigh evidence when sufficient)
State v. Rojo, 971 P.2d 829 (N.M. 1999) (jury may reject defendant’s version of facts)