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State v. Seonia
A-1-CA-36320
N.M. Ct. App.
Oct 25, 2017
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Background

  • Defendant Lance Seonia was convicted in metropolitan court of DWI and failure to maintain a traffic lane; the district court affirmed on an on-record appeal and this appeal followed.
  • Officer observed Defendant straddling the double-yellow line (driving in two lanes) and smelled a strong odor of alcohol.
  • Defendant initially denied drinking, later admitted to consuming three pints of beer.
  • Defendant performed poorly on some field sobriety tests, showing lack of coordination and failure to follow instructions.
  • Breath test detected alcohol levels within the legal limit.
  • Appellate court issued a proposed summary disposition to affirm; Defendant opposed but did not identify factual inaccuracies or legal error persuasive to the court.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the evidence was sufficient to convict for DWI under the "impaired to the slightest degree" theory State argued the combination of driving behavior, odor of alcohol, admission of drinking, poor field sobriety performance, and breath test supported impairment Seonia argued the evidence was insufficient to prove impairment to the slightest degree Court affirmed: viewing evidence in light most favorable to verdict, evidence was sufficient to support DWI conviction

Key Cases Cited

  • State v. Sanchez, 131 N.M. 355, 36 P.3d 446 (N.M. Ct. App. 2001) (defines "under the influence" as impaired to the slightest degree affecting safe vehicle operation)
  • State v. Cunningham, 128 N.M. 711, 998 P.2d 176 (N.M. 2000) (appellate review views evidence in light most favorable to guilty verdict)
  • State v. Rojo, 126 N.M. 438, 971 P.2d 829 (N.M. 1999) (appellate courts disregard evidence and inferences supporting a different result)
  • State v. Notah-Hunter, 137 N.M. 597, 113 P.3d 867 (N.M. Ct. App. 2005) (similar facts—odor, admissions, failed sobriety tests, lane violation—sufficient for slightest-degree impairment conviction)
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Case Details

Case Name: State v. Seonia
Court Name: New Mexico Court of Appeals
Date Published: Oct 25, 2017
Docket Number: A-1-CA-36320
Court Abbreviation: N.M. Ct. App.