State v. Ryals, 35,820

Defendant Shaun Ryals convicted of second-degree murder, arson, three counts of tampering with evidence, and receiving/transferring a stolen vehicle; appealed one tampering conviction on double jeopardy grounds.
The two tampering convictions challenged were based on (1) transporting the victim’s body in the trunk and (2) setting the body on fire in the trunk.
Record showed the transporting and burning occurred in the same vehicle, in close temporal sequence, with no intervening events identified.
The State argued the acts were distinct (transport vs. destruction) and involved different intents (transporting evidence vs. destroying evidence).
Court compared facts to State v. Saiz and State v. Urioste to assess "indicia of distinctness" (timing, location, sequencing, intent).
Court concluded the transportation and burning constituted a single continuous course of conduct with a single intent to prevent prosecution, so only one tampering conviction was permissible; one tampering conviction reversed and case remanded for sentence adjustment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether two tampering-with-evidence convictions (transporting body; burning body) violate double jeopardy	The transporting and the burning are at least two distinct acts with different intents, supporting separate convictions	The transporting and burning were part of a single continuous course of conduct with one intent to prevent prosecution, so only one conviction allowed	Reversed one tampering conviction; acts lacked sufficient indicia of distinctness and support only a single conviction

State v. Saiz, 144 N.M. 663, 191 P.3d 521 (N.M. 2008) (distinguishes unit-of-prosecution for tampering by focusing on timing, location, sequencing; transporting and disposing of a body can be a single offense)
State v. Urioste, 267 P.3d 820 (N.M. Ct. App. 2011) (upheld separate tampering convictions where predicate acts occurred at different times and places)
State v. Belanger, 146 N.M. 357, 210 P.3d 783 (N.M. 2009) (discussed in relation to tampering precedents; abrogated on other grounds)