State v. Seigling, 2017 NMCA 35

Background

Defendant Seigling was indicted Sept. 5, 2014, and after the Second Judicial District’s local case-management rule (LR2-400) took effect Feb. 2, 2015, the case was placed on Track 1 with trial set July 20, 2015.
Defense subpoenas scheduled four officer interviews for Feb. 24, 2015; two officers failed to appear and one was unavailable, and defense moved to exclude those witnesses and to suppress/dismiss for discovery violations.
Defense also alleged the State failed to produce lapel camera recordings and two detective interviews; the State said a speed letter and later notice of availability were provided but copies were not timely delivered.
The district court granted defense motion excluding witnesses and suppressing all audio/visual evidence; the State appealed.
The Court of Appeals analyzed whether the local rule’s mandatory/mandatory-sanction provisions conflict with New Mexico precedent limiting exclusionary sanctions (chiefly State v. Harper) and whether the district court properly applied sanctioning principles.
The Court of Appeals reversed the exclusions and suppression, holding Harper’s limits still apply where no direct conflict with the local rule exists and the district court failed to consider lesser sanctions, intent/bad faith, and concrete prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether LR2-400 (local rule) supersedes Harper and other precedent limiting exclusionary sanctions	LR contemplates mandatory sanctions for timeline/discovery violations and its non-conflict clause allows limiting prior law only where irreconcilable; thus local rule controls in many instances	Harper and precedent limit exclusion/dismissal absent bad faith, prejudice, and consideration of lesser sanctions; local rule should not eviscerate those protections	The court reconciled LR2-400 with Harper: where no direct conflict exists Harper still applies; LR2-400 does not automatically authorize exclusion without considering Harper factors
Exclusion of witnesses for failure to appear at Feb. 24 interviews	State: no LR deadline had yet been violated (scheduling order omitted interview deadline) and there remained months to reschedule; exclusion was excessive	Defense: officers failing to comply with subpoenas and prosecutors’ failure to assist justified exclusion under LR2-400 sanctions provisions	Reversed. District court did not find intent/bad faith, prejudice, or consider lesser sanctions as required by Harper; mandatory sanctions provision did not compel exclusion here because no LR deadline had been breached
Suppression of audio/visual evidence for late production	State: provided a speed letter and later notice; argued prejudice not shown and production occurred well before trial/motions deadline	Defense: LR2-400 requires copies of documentary and audio/visual materials at arraignment or within five days of written waiver; speed letter alone is not compliance	Reversed. State clearly violated production timelines and sanctions were appropriate, but the court must consider lesser sanctions, culpability, and prejudice before imposing exclusion; blanket suppression was not justified on these facts

Key Cases Cited

State v. Harper, 266 P.3d 25 (N.M. 2011) (exclusion of witnesses improper absent intentional refusal to comply with court order, tangible prejudice, and consideration of lesser sanctions)
State v. Guerra, 278 P.3d 1031 (N.M. 2012) (extreme sanction of exclusion should be applied sparingly)
Starko, Inc. v. N.M. Human Servs. Dep’t, 333 P.3d 947 (N.M. 2014) (plain meaning rule for statutory/rule text interpretation)
Gonzales v. Surgidev Corp., 899 P.2d 594 (N.M. 1995) (trial court must reasonably explore meaningful alternatives before dismissal)
State v. Morris, 364 P.2d 348 (N.M. 1961) (written orders supersede oral rulings)