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