State v. Martinez

• Decision Date: 01 November 2021
• Docket Number: S-1-SC-37938
• Parties: STATE OF NEW MEXICO, Plaintiff-Respondent, v. JULIAN A. MARTINEZ, Defendant-Petitioner.
• Court: Supreme Court of New Mexico

STATE OF NEW MEXICO, Plaintiff-Respondent,
v.
JULIAN A. MARTINEZ, Defendant-Petitioner.

No. S-1-SC-37938

Supreme Court of New Mexico

November 1, 2021

ORIGINAL PROCEEDING ON CERTIORARI Robert A. Aragon, District Judge

Bennett J. Baur, Chief Public Defender Charles Agoos, Assistant Appellate Defender Santa Fe, NM for Petitioner

Hector H. Balderas, Attorney General Eran Shemuel Sharon, Assistant Attorney General Santa Fe, NM for Respondent

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OPINION

DAVID K. THOMSON, JUSTICE

{¶1} In this opinion, we clarify that the return of a jury's guilty verdict does not divest a district court of its inherent authority to determine whether the evidence presented at trial was legally insufficient to support a conviction. We also conclude that the State may appeal such a determination without offending the principles of double jeopardy. We reverse and remand to the Court of Appeals for further proceedings to consider the sufficiency of the evidence.

I. BACKGROUND

{¶2} The Court of Appeals determined, without actually reviewing the sufficiency of the evidence, that the district court did not have the authority to review the sufficiency of the evidence after it accepted the jury's verdict. See State v. Martinez, A-1-CA-37798, mem. op. ¶¶ 1-3 (N.M. Ct. App. Sept. 16, 2019). Therefore, we recount only the facts relevant to whether the district court had authority to rule as it did, which are minimal and, primarily, procedural.

{¶3} Defendant Julian A. Martinez was charged with committing multiple crimes, including criminal sexual penetration, battery against a household member, and false imprisonment. At trial, the district court denied Defendant's motion for a directed verdict, determining that there was sufficient evidence presented to submit the

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questions of guilt on five counts to the jury. The jury returned two guilty verdicts, convicting Defendant of criminal sexual penetration and battery against a household member, and the district court accepted the verdicts. Two days later, on its own motion, the district court vacated both convictions, concluding that the State failed to establish that Defendant was the person who committed the crimes. The State appealed.

{¶4} The Court of Appeals summarily reversed the district court in a nonprecedential, memorandum opinion, relying almost entirely on language quoted from State v. Torrez, 2013-NMSC-034, ¶ 10, 305 P.3d 944: "A district court does not have the authority to override a jury's verdict and enter a verdict different than that handed down by the jury." Martinez, A-1-CA-37798, mem. op. ¶¶ 2-3. Defendant petitioned this Court for certiorari review, which we granted. See Rule 12-502 NMRA (providing for "review of decisions of the Court of Appeals"). We now determine whether a district court's authority to review the sufficiency of the evidence ends when the jury returns a verdict. We conclude it does not.

II. ANALYSIS

{¶5} Whether a district court has the authority to determine the evidence was insufficient postverdict is a legal question we review de novo. See State v. Gonzales, 2005-NMSC-025, ¶ 21, 138 N.M. 271, 119 P.3d 151 (observing that questions which

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"require a court to exercise judgment about the values that animate legal principles" or "consider abstract legal doctrines" and "balance competing legal interests" are subject to de novo review (internal quotation marks and citations omitted)); State v. Frank, 2002-NMSC-026, ¶10, 132 N.M. 544, 52 P.3d 404 (observing that "matters of law," such as whether a court has the authority to act, are reviewed de novo (internal quotation marks and citation omitted)).

{¶6} The New Mexico Rules of Criminal Procedure "are intended to provide for the just determination of criminal proceedings [and] shall be construed to secure simplicity in procedure, fairness in administration and the elimination of unjustifiable expense and delay." Rule 5-101(B) NMRA. These rules are applied with an understanding of a court's "inherent power to see that a [defendant's] fundamental rights are protected in every case" and that "[every] court has the power, in its discretion, to relieve [a defendant of the error] and to see that injustice is not done." State v. Cunningham, 2000-NMSC-009, ¶ 12, 128 N.M. 711, 998 P.2d 176 (internal quotation marks and citation omitted). "Because a court's inherent power is at the core of judicial authority, it is the province of this Court to define the contours of that power." State ex rel. N.M. State Highway and Transp. Dep't v. Baca, 1995-NMSC-033, ¶ 20, 120 N.M. 1, 896 P.2d 1148.

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{¶7} With this in mind, we conclude that nothing in Torrez or the cases upon which the State relies alters a district court's inherent authority to determine that the evidence presented was legally insufficient to sustain a conviction. See Martinez, A-1-CA-37798, mem. op. ¶¶ 2-3. This conclusion does not alter, but rather strengthens, two requirements of our Rules of Criminal Procedure: (1) A district court's duty to examine the sufficiency of the evidence prior to submitting a question of guilt to the jury and (2) the prohibition of a district court from invading the fact-finding province of a jury. See Rule 5-607(E), (K) NMRA (establishing the "order of trial" and providing that "out of the presence of the jury, the court shall determine the sufficiency of the evidence, whether or not a motion for directed verdict is made"); Rule 5-701(A) NMRA ("If the defendant is found guilty, a judgment of guilty shall be rendered. If the defendant has been acquitted, a judgment of not guilty shall be rendered.").

{¶8} Whether the evidence is sufficient to sustain a verdict is a question that "may and should be raised by the court of its own motion, if necessary to...