State v. Baca – Commitment for life can be appealed directly to New Mexico Supreme Court

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After Fidel Baca, Sr. was found dead with an enormous pickaxe sticking out of his chest, Defendant Manuel Baca was charged with his murder.  The district court found that Manuel had committed first degree murder, but was not competent to stand trial, and therefore ordered Manuel to be committed for life, with periodic examinations to determine whether he was competent to stand trial.  Manuel appealed directly to the New Mexico Supreme Court, arguing that there was insufficient evidence to show that he had committed the murder. After concluding that it could hear direct appeals from life commitment orders, the Court affirmed.

Article VI, section 2 of the New Mexico Constitution promises that every “aggrieved party shall have an absolute right to one appeal.” But which court hears the appeal?  Ordinarily, direct appeals are heard by the court of appeals.  However, “appeals from a judgment of the district court imposing a sentence of death or life imprisonment shall be taken directly to the supreme court.”  There appears to be no reason to prefer one over the other; while the court of appeals has more experience deciding arguments on the sufficiency of the evidence, the supreme court has more experience deciding matters related to life sentences.

It would have been easy for the Court to avoid jurisdiction here.  Direct appeals are available only sentences of life imprisonment.  Here, the defendant had not been sentenced; indeed, the commitment hearing was not a criminal prosecution.  But the Court chose a different approach. Noting that a lifetime commitment order “is equivalent to the deprivation of liberty under a lifetime sentence,” it concludes that the two are “effectively” the same, and that a direct appeal is appropriate under Article XI, Section 2.

Having decided that it had jurisdiction, the Court turned to Defendant’s sufficiency of the evidence argument.  Even for the best New Mexico appeals lawyer, a sufficiency of the evidence argument is one of the most difficult arguments to win on appeal.  Sufficiency will be upheld so long as a rational fact finder could have found from the evidence that the crime was committed.  This is true even if a different fact finder could have concluded there was no crime.  This is one of the most difficult standards of review to win.

Here, the Court had no difficulty finding sufficient evidence that the Defendant had committed first degree murder. Apparently, the Defendant only contested the evidence that he had deliberately intended to kill Fidel. But the evidence showed that the defendant had made statements that he wanted Fidel dead, that he broke into Fidel’s trailer, armed himself with a massive pickaxe, hit Fidel with the axe some eighteen times, and waited until Fidel was dead before calling emergency services. The Court concluded that a rational fact finder could find that this evidence showed an intent to kill Fidel, a conclusion that seems unassailable.

At the end of the day, this opinion will not be terribly significant for New Mexico. Few defendants are committed for life, and it is not clear that it makes a difference which court hears the appeal. And, of course, another sufficiency of the evidence affirmance is hardly earth-shattering. But it’s nice to have a solid, concise 5-0 opinion after Fry v. Lopez.

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