A-1-CA-36304•April 5, 2018- State of New Mexico v. Steven Vanderdussen, No. A-1-CA-36304
April 5, 2018- State of New Mexico v. Steven Vanderdussen, No. A-1-CA-36304
A-1-CA-36304Nmctapp
Gesamter Gesetzestext
IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO 1 Opinion Number: 2 Filing Date: April 5, 2018 3 No. A-1-CA-36304 4 STATE OF NEW MEXICO, 5 Plaintiff-Appellee, 6 v. 7 STEVEN VANDERDUSSEN, 8 Defendant-Appellant. 9 APPEAL FROM THE DISTRICT COURT OF CURRY COUNTY 10 Fred T. Van Soelen, District Judge 11 Hector H. Balderas, Attorney General 12 Santa Fe, NM 13 John Kloss, Assistant Attorney General 14 Albuquerque, NM 15 for Appellee 16 Lindsey Law Firm, L.L.C. 17 Daniel R. Lindsey 18 Clovis, NM 19 for Appellant 20 Filed Court of Appeals of New Mexico 4/5/2018 12:59 PM Office of the Clerk Mark Reynolds
OPINION 1
KIEHNE, Judge. 2
{1} Defendant appeals from the district court’s order denying dismissal of the 3
charges against him on double jeopardy grounds. The district court ruled that the 4
magistrate court properly declared a mistrial based on manifest necessity, where a 5
juror was discharged for stating that she could not be impartial after deliberations had 6
begun and the alternate jurors were dismissed from the courtroom. Defendant argues 7
that the magistrate court failed to consider less severe alternatives to a 8
mistrial—namely, the magistrate court refused to call back the alternate jurors who 9
remained in the courthouse—and, therefore, the mistrial was not based on manifest 10
necessity. We hold that the mistrial was justified by manifest necessity and affirm the 11
district court’s denial of Defendant’s motion to dismiss. 12
PROCEDURAL BACKGROUND 13
{2} To frame our examination of the mistrial, we first address the limits of the 14
record before us and the roles of the courts through which this case has traveled. 15
Because charges were originally filed against Defendant in magistrate court, which 16
is not a court of record, there is no record of the events that occurred there. See NMSA 17
1978, § 35-1-1 (1968) (establishing magistrate courts as courts not of record); Black’s 18
Law Dictionary 431 (10th ed. 2014) (defining “court of record” as “[a] court that is 192 required to keep a record of its proceedings”). After the magistrate court declared a 1 mistrial, the State refiled the same charges in district court. In district court, 2 proceedings are held de novo. Cf. NMSA 1978, § 35-13-2(A) (1996) (“Appeals from 3 the magistrate courts shall be tried de novo in the district court.”); see State ex rel. 4 Bevacqua-Young v. Steele, 2017-NMCA-081, ¶ 9, 406 P.3d 547 (“In a de novo appeal 5 to the district court, there is a new trial on the entire case—that is, on both questions 6 of fact and issues of law—conducted as if there had been no trial in the first instance.” 7 (internal quotation marks and citation omitted)). In the de novo proceedings here, 8 Defendant filed numerous motions including a motion to dismiss for violation of the 9 Double Jeopardy Clause, the subject of this appeal. Because the district court was not 10 sitting in a typical appellate capacity, the district court was not bound by the 11 magistrate court’s decisions and was required to make an independent determination 12 of whether manifest necessity supported the magistrate court’s declaration of a 13 mistrial. See State v. Foster, 2003-NMCA-099, ¶¶ 9, 19, 134 N.M. 224, 75 P.3d 824 14 (holding that because the magistrate court is not a court of record, appeals from there 15 are heard de novo in district court, which required the district court to decide anew, 16 without deference to the magistrate court, whether a mistrial was warranted). The 17 district court, however, was bound by events that transpired in magistrate court and 18 therefore was required to base its independent judgment on the limited record brought 19
3
before it and the arguments made by counsel in district court. See id. ¶¶ 19-20; City 1
of Farmington v. Piñon-Garcia, 2013-NMSC-046, ¶ 12, 311 P.3d 446 (stating that the 2
history of a case in a court not of record is not disregarded when appealed to the 3
district court for a trial de novo). 4
{3} The State raises arguments in this case about Defendant’s failure to more fully 5
develop the record to establish error. It appears that, at least in the context of a 6
challenge in district court to a plea agreement entered into in magistrate court, the 7
district court is permitted to take evidence to clarify the limited record from magistrate 8
court. See State v. Gallegos, 2007-NMCA-112, ¶¶ 16, 18, 142 N.M. 447, 166 P.3d 9
1101 (explaining that the district court properly conducted an evidentiary hearing to 10
reconstruct the magistrate proceedings to allow it to fulfill its “obligation to determine 11
the validity of the plea in order to determine its jurisdiction over the appeal”). Our 12
Supreme Court has also explained that it is permissible for the district court to hold 13
a hearing to reconstruct the magistrate proceedings when asked to decide whether the 14
magistrate court acquitted the defendant on the merits or dismissed the complaint for 15
a procedural violation. See State v. Baca, 2015-NMSC-021, ¶¶ 2, 27, 352 P.3d 1151. 16
{4} In this case, the district court held a hearing on Defendant’s motion to dismiss 17
and relied on the limited magistrate court record and the parties’ stipulation to facts, 18
including the stipulation to the defense’s offer of proof, in order to clarify events in 194
magistrate court. There was no objection to this process. Also, neither the parties nor 1
the district court asked that the record be supplemented with testimony from the 2
magistrate judge to determine whether the magistrate judge considered less severe 3
alternatives to a mistrial. We therefore decline the State’s request to hold that it is a 4
defendant’s burden to re-create a complete record of the magistrate court proceedings. 5
See Rule 12-321(A) NMRA (“To preserve an issue for review, it must appear that a 6
ruling or decision by the trial court was fairly invoked.”). In this appeal, we simply 7
rely on the facts as they were presented to, and found by, the district court to review 8
whether the declaration of a mistrial was an abuse of discretion. See State v. Baca, 9
2015-NMSC-021, ¶ 25 (stating that we review double jeopardy claims de novo and 10
defer to the facts found by the district court, not the magistrate court, “because it was 11
the district court that had to find the facts on which to apply the law in ruling on the 12
motion to dismiss”); see also State v. Gutierrez, 2014-NMSC-031, ¶ 21, 333 P.3d 247 13
(noting that “manifest necessity mistrial rulings are reviewed for abuse of discretion”). 14
FACTUAL BACKGROUND 15
{5} Defendant was charged and tried in magistrate court for misdemeanor DWI and 16
failure to maintain his lane. The case was tried before eight jurors—six regular jurors 17
and two alternates. After the trial concluded and the jury was instructed on the law, 18
the magistrate court dismissed the two alternate jurors and excused the six-person jury 195
from the courtroom to deliberate. Approximately five minutes into deliberations, a 1
juror informed the magistrate judge by note that she could not be impartial based on 2
her personal and business dealings with Defendant’s family. The magistrate judge 3
walked into the courtroom, showed the note to the parties, and directed the parties to 4
discuss the note in chambers. Defense counsel immediately turned to his legal 5
assistant and instructed her to leave the courtroom to see if she could find the two 6
alternate jurors. Defense counsel accompanied his legal assistant and saw that the two 7
alternate jurors were still in the courthouse, standing in the lobby at a counter, doing 8
paperwork or waiting to do paperwork. Defense counsel immediately walked back to 9
chambers and asked the magistrate judge to call the alternate jurors back to determine 10
whether they could still serve as impartial jurors and replace the biased juror. The 11
State asked for a mistrial, and the defense objected. The magistrate judge rejected the 12
defense’s proposal without attempting to locate and question the alternate jurors, and 13
declared a mistrial. Thereafter, the magistrate court entered a written order declaring 14
a mistrial due to manifest necessity. 15
{6} After hearing the parties’ presentation of the facts and legal argument on the 16
events in magistrate court, the district court took the matter under advisement. The 17
district court also considered the parties’ briefs on the matter and entered a detailed 18
letter decision. The district court observed a lack of dispute that good cause existed 196
to dismiss the juror who expressed bias regarding Defendant and framed the question 1
as whether the magistrate court adequately inquired into alternatives to a mistrial. The 2
district court further observed that the absence of a record made it difficult to 3
determine whether alternatives to a mistrial were considered and acknowledged the 4
parties’ stipulation that the magistrate judge did not question the alternate jurors about 5
their ability to serve after they were released. On the facts presented to it, the district 6
court concluded that manifest necessity justified a mistrial, based on the district court 7
rule governing alternate jurors, i.e. Rule 5-605(B) and (C) NMRA, and on a Supreme 8
Court opinion holding that Rule 5-605 does not permit substitution of an alternate 9
juror after jury deliberations have begun. See State v. Sanchez, 2000-NMSC-021, ¶¶ 10
1, 23, 129 N.M. 284, 6 P.3d 486. Defendant appeals from this ruling. 11
DISCUSSION 12
{7} The Double Jeopardy Clause guarantees that no person shall be “twice put in 13
jeopardy” for the same offense. U.S. Const. amend. V; N.M. Const. art. II, § 15. 14
“However, the principles of double jeopardy do not prohibit retrying a defendant, even 15
over the defendant’s objections, after a mistrial that was justified by manifest 16
necessity.” State v. Desnoyers, 2002-NMSC-031, ¶ 33, 132 N.M. 756, 55 P.3d 968 17
(internal quotation marks and citation omitted), abrogated on other grounds as 18
recognized by State v. Rivas, 2017-NMSC-022, ¶ 47, 398 P.3d 299. The burden of 197
proving “manifest necessity” falls on the prosecutor, and the magnitude of that burden 1
is appropriately characterized by its very terms. Arizona v. Washington, 434 U.S. 497, 2
505 (1978). Two requirements must be met for an appellate court to uphold a mistrial 3
for manifest necessity. “First, the circumstances necessitating the mistrial must be 4
extraordinary ones, sufficient to override the defendant’s double jeopardy interests. 5
Second, the trial judge must determine whether an alternative measure—less drastic 6
than a mistrial—can alleviate the problem so that the trial can continue to an impartial 7
verdict.” State v. Yazzie, 2010-NMCA-028, ¶ 13, 147 N.M. 768, 228 P.3d 1188 8
(internal quotation marks and citation omitted). 9
{8} As indicated above, we review the trial court’s declaration of a mistrial for 10
abuse of discretion, which in this case is the standard we apply to the district court’s 11
de novo ruling. See Baca, 2015-NMSC-021, ¶ 25. The degree of deference and 12
scrutiny we accord the declaration of a mistrial under the abuse of discretion standard 13
depends on the reason for the mistrial. See Washington, 434 U.S. at 508-10 (providing 14
examples that fall within the continuum of appellate scrutiny and deference accorded 15
to mistrials); Gutierrez, 2014-NMSC-031, ¶ 22 (acknowledging that while abuse of 16
discretion is the appropriate standard of review for mistrials, the strictest scrutiny is 17
applied to mistrials ordered for missing prosecution witnesses). 188
{9} The parties in this case do not dispute that it was appropriate to remove the 1
deliberating juror who said she could not be impartial from the jury, which left only 2
five jurors. There also is no dispute that a jury in magistrate court must be comprised 3
of six jurors. See NMSA 1978, § 35-8-3(A) (1974); Rule 6-605(A). Thus, the dispute 4
is focused entirely on the second requirement for a finding of manifest 5
necessity—whether there was a less drastic alternative to a mistrial that would 6
“alleviate the problem so that the trial [could] continue to an impartial verdict.” 7
Yazzie, 2010-NMCA-028, ¶ 13 (internal quotation marks and citation omitted). 8
{10} Defendant argues that the district court’s ruling, relying on district court Rule 9
5-605, overlooks the fact that procedures in magistrate court differ from those in 10
district court. As Defendant points out, Rule 5-605(C) mandates that in a noncapital 11
case before the district court, “an alternate juror who does not replace a regular juror 12
shall be discharged before the jury retires to consider its verdict.” Id. The magistrate 13
court rules have no such requirement for the discharge of alternate jurors. Defendant 14
informs us that, unlike in district court, it is common practice in the Clovis Magistrate 15
Court for the judge to ask counsel whether they wish to retain the alternate jurors 16
during deliberations or release them. Defendant contends that the magistrate court 17
should have explored the possibility of replacing the biased juror with one of the 18
alternates and refers this Court to several federal cases that permit, in the absence of 199
prejudice to the defendant, the substitution of an alternate juror who had been 1
dismissed when the case was submitted to the jury for deliberation—the practice is 2
called “post-submission substitution.” 3
{11} We agree with Defendant that generally the magistrate court is not required to 4
follow a district court rule in the absence of a similar magistrate court rule, and we 5
further acknowledge that, typically, the district court is required to apply the rules of 6
the magistrate court when considering issues in de novo proceedings. See State v. 7
Sharp, 2012-NMCA-042, ¶ 8, 276 P.3d 969 (emphasizing that, in de novo 8
proceedings, the district court is required to apply the rules of the lower, non-record 9
court in its independent consideration of an issue decided below). Under the 10
circumstances, however, we are not persuaded that the district court erred by relying 11
on the district court rule and New Mexico case law governing the discharge of 12
alternate jurors. 13
{12} Even assuming that the magistrate court usually gives the parties the option of 14
retaining alternate jurors during deliberations, and assuming that this is permitted in 15
New Mexico, the parties in the current case agreed that the alternate jurors could be 16
excused. There is no indication that the magistrate court advised the alternate jurors 17
that they continued to be bound by their oath and obligations as alternate jurors when 18
it discharged them. Thus, the alternate jurors were discharged from jury duty, left the 1910
courtroom, and were present in the courthouse lobby. See State v. Rodriguez, 1
2006-NMSC-018, ¶ 7, 139 N.M. 450, 134 P.3d 737 (recognizing a presumption of 2
prejudice “once a juror has left the presence and control of the court into an area 3
occupied by the general public”). The magistrate court rules contain no provisions for 4
the use of alternate jurors or the discharge of jurors. While nothing in the magistrate 5
court rules mandates the use of district court rules, we cannot say it was error for the 6
magistrate court to use the rules adopted for district courts in New Mexico as guidance 7
in this situation. Cf. State v. Romero, 2014-NMCA-063, ¶¶ 6-8, 327 P.3d 525 (finding 8
guidance, where logical, in civil procedure on a matter where the Rules of Criminal 9
Procedure were silent). 10
{13} Furthermore, our Supreme Court has declared by rule and case law that the New 11
Mexico policy governing alternate jurors does not authorize post-submission 12
substitution of jurors. Sanchez, 2000-NMSC-021, ¶ 21 (“In the absence of a rule 13
authorizing post-submission substitution, however, we interpret our rule as not 14
authorizing post-submission substitution.”). Our Supreme Court considered the 15
approach Defendant advocates in this case and determined that such an approach was 16
rejected in our state by the absence of a rule authorizing it. Id. ¶¶ 21-23. Although our 17
Supreme Court felt bound by the restrictive language of Rule 5-605, it acknowledged 18
that some changes to the rule may be constitutionally permissible and invited future 1911
consideration of changes to it. Id. ¶ 21 (“We are not at liberty, in a decisional context, 1
to change the language of our rule. If there is to be a change in the rule or the policy 2
underlying the rule, it must come through the normal rule-making process.”(alteration, 3
omissions, internal quotation marks, and citation omitted)). Our Supreme Court, 4
however, has not altered Rule 5-605 since the opinion in Sanchez was published in 5
2000. Sanchez then states the prevailing view in New Mexico that a “post-submission 6
substitution is error under Rule 5-605; it is error that creates a presumption of 7
prejudice; the state must show under the circumstances . . . that the trial court took 8
adequate steps to ensure the integrity of the jury process.” Id. ¶ 23. 9
{14} We have no case law deciding whether, under any circumstances, it was an 10
abuse of discretion to declare a mistrial based on a refusal to make a post-submission 11
substitution in the jury after the alternate jurors were dismissed. Cf. State v. Sanchez, 12
1995-NMSC-053, ¶ 16, 120 N.M. 247, 901 P.2d 178 (holding that the district court 13
did not abuse its discretion by denying the defendants’ motion for a retrial and 14
refusing the defendants’ request to replace a juror “with an alternate juror after the 15
jury had retired to deliberate, and the alternate jurors had been dismissed for more 16
than one day[,]” where the defendants were aware from voir dire of the juror’s 17
relationship to an employee for the prosecution).We conclude that a higher degree of 18
deference is appropriate when the court’s refusal to make a post-submission 1912
substitution, after alternate jurors were already dismissed, resulted in a mistrial given 1
our Supreme Court’s prevailing view that a post-submission substitution is error that 2
creates a presumption of prejudice. 3
{15} In this case, not only were the alternate jurors discharged and present in a public 4
place, the deliberating juror Defendant sought to replace was removed, not for illness 5
or another case-neutral emergency, but for a late disclosure of bias. See Washington, 6
434 U.S. at 513 (“There are compelling institutional considerations militating in favor 7
of appellate deference to the trial judge’s evaluation of the significance of possible 8
juror bias.”); State v. Saavedra, 1988-NMSC-100, ¶ 9, 108 N.M. 38, 766 P.2d 298 9
(stating that where “the underlying issue involves a deadlocked jury or possible jury 10
bias, the trial judge should be allowed broad discretion whether to declare a mistrial”); 11
cf. Sanchez, 2000-NMSC-021, ¶¶ 4, 9, 13, 16 (cataloging cases across the country 12
involving post-submission substitution where a deliberating juror became disabled, 13
ill, or incapacitated, and holding that the district court erred by making a post- 14
submission substitution where the district court failed to take adequate precautions to 15
protect the deliberative process, where a deliberating juror was discharged for illness). 16
{16} Although the timing of the biased juror’s disclosure was only five minutes into 17
deliberations, Defendant’s own proffer in district court to present testimony from one 18
of the other deliberating jurors demonstrates that five minutes is not an insignificant 1913 time to deliberate; rather, it can be adequate time for jurors to reach certain 1 conclusions. Indeed, Defendant asserted in the district court that “[t]he jury was five 2 (5) to one (1) for acquittal.” Our case law has long recognized that, generally, “a lone 3 biased juror undermines the impartiality of an entire jury[.]” State v. Gallegos, 2009- 4 NMSC-017, ¶ 22, 146 N.M. 88, 206 P.3d 993 (internal quotation marks and citation 5 omitted). We agree with the State that the timing of the juror’s confession of 6 bias—after hearing the entire trial and having been excused to deliberate with the jury 7 for even five minutes—gives rise to grave concerns that the juror’s bias could have 8 tainted or contaminated the remaining jurors. See State v. Mann, 2002-NMSC-001, 9 ¶ 27, 131 N.M. 459, 39 P.3d 124 (“Jury tampering and juror bias present the clearest 10 examples of potentially improper influences upon a jury[.]”); cf. Gallegos, 11 2009-NMSC-017, ¶ 23 (holding that a mistrial was not warranted given the early stage 12 of the trial, the absence of a claim that there were improper communications among 13 the jurors suggesting bias, the discreet manner in which the biased juror alerted the 14 judge, and the early replacement of the juror with an alternate). The Supreme Court 15 of the United States has stated that “[n]either party has a right to have his case decided 16 by a jury which may be tainted by bias; in these circumstances, the public’s interest 17 in fair trials designed to end in just judgements must prevail over the defendant’s 18 valued right to have his trial concluded before the first jury impaneled.” Washington, 19
14
434 U.S. at 516 (internal quotation marks and citation omitted). This Court also has 1
acknowledged that “where the irregularity involves possible partiality within the jury, 2
it has been more often held that the public interest in fair verdicts outweighs [the] 3
defendant’s interest in obtaining a verdict by his first choice of jury.” State v. C. De 4
Baca, 1975-NMCA-120, ¶ 8, 88 N.M. 454, 541 P.2d 634. 5
{17} We recognize that the limited record available does not disclose the extent to 6
which the magistrate court considered less drastic alternative measures to a mistrial, 7
and we recognize that our case law requires some duty to inquire into those 8
alternatives, but it is “ ‘not clear as to what kind or how much of an inquiry into 9
alternatives is necessary.’ ” State v. Salazar, 1997-NMCA-088, ¶ 14, 124 N.M. 23, 10
946 P.2d 227 (alteration omitted) (quoting C. De Baca, 1975-NMCA-120, ¶ 10). 11
Nonetheless, we are not persuaded that, where faced with this risk of jury 12
contamination, the trial court was required to explore the proposed alternative to a 13
mistrial—a post-submission substitution—which itself would have created a 14
presumption of prejudice and would not have alleviated or even addressed the 15
potential taint to the remaining jurors. See Yazzie, 2010-NMCA-028, ¶ 13 (explaining 16
that the second requirement for manifest necessity requires the trial judge to 17
“determine whether an alternative measure—less drastic than a mistrial—can alleviate 18
the problem so that the trial can continue to an impartial verdict” (internal quotation 1915
marks and citation omitted)). We have said that the proposed alternatives to a mistrial 1
must be feasible or reasonable. See State v. Messier, 1984-NMCA-085, ¶¶ 13-14, 101 2
N.M. 582, 686 P.2d 272. Where the proposed alternative to a mistrial carries a 3
likelihood of reversal, that alternative would not be reasonable. 4
{18} We will not hold that it was an abuse of discretion, after the disclosure of a 5
deliberating juror’s bias, for the magistrate court to refuse a measure that would 6
violate our only rule governing the discharge of alternate jurors in criminal trials and 7
would also result in presumptive prejudice. See Washington, 434 U.S. at 500-02, 513 8
(explaining that the absence of an express finding from the trial court that alternatives 9
to a mistrial were considered does not prevent a court from affording great deference 10
to a trial judge’s assessment of the potential bias of a jury); Sanchez, 2000-NMSC- 11
021, ¶¶ 21-23. We agree with the district court and hold that the mistrial was justified 12
by manifest necessity. See Saavedra, 1988-NMSC-100, ¶ 16 (concluding that where 13
there are “sufficient reasons presented to justify declaration of a mistrial, . . . the fact 14
that the judge would have been in a better position to assess the situation had he taken 15
the steps suggested by the defendant” does not preclude an affirmance of manifest 16
necessity for a mistrial). 17
CONCLUSION 18OCR transcription for search; preserved printed pages are authoritative
10
11
12
13
14
15
16
17
18
19
20
Filed
Court of Appeals of New Mexico
4/5/2018 12:59 PM
IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO
Opinion Number:
Filing Date: April 5, 2018
No. A-1-CA-36304
STATE OF NEW MEXICO,
Plaintiff-Appellee,
v.
STEVEN VANDERDUSSEN,
Defendant-Appellant.
APPEAL FROM THE DISTRICT COURT OF CURRY COUNTY
Fred T. Van Soelen, District Judge
Hector H. Balderas, Attorney General
Santa Fe, NM
John Kloss, Assistant Attorney General
Albuquerque, NM
for Appellee
Lindsey Law Firm, L.L.C.
Daniel R. Lindsey
Clovis, NM
for Appellant
Ma
of the Clerk
[>
—_—
rk Reynolds
OPINION 1
KIEHNE, Judge. 2
{1} Defendant appeals from the district court’s order denying dismissal of the 3
charges against him on double jeopardy grounds. The district court ruled that the 4
magistrate court properly declared a mistrial based on manifest necessity, where a 5
juror was discharged for stating that she could not be impartial after deliberations had 6
begun and the alternate jurors were dismissed from the courtroom. Defendant argues 7
that the magistrate court failed to consider less severe alternatives to a 8
mistrial—namely, the magistrate court refused to call back the alternate jurors who 9
remained in the courthouse—and, therefore, the mistrial was not based on manifest 10
necessity. We hold that the mistrial was justified by manifest necessity and affirm the 11
district court’s denial of Defendant’s motion to dismiss. 12
PROCEDURAL BACKGROUND 13
{2} To frame our examination of the mistrial, we first address the limits of the 14
record before us and the roles of the courts through which this case has traveled. 15
Because charges were originally filed against Defendant in magistrate court, which 16
is not a court of record, there is no record of the events that occurred there. See NMSA 17
1978, § 35-1-1 (1968) (establishing magistrate courts as courts not of record); Black’s 18
Law Dictionary 431 (10th ed. 2014) (defining “court of record” as “[a] court that is 19
2
required to keep a record of its proceedings”). After the magistrate court declared a 1
mistrial, the State refiled the same charges in district court. In district court, 2
proceedings are held de novo. Cf. NMSA 1978, § 35-13-2(A) (1996) (“Appeals from 3
the magistrate courts shall be tried de novo in the district court.”); see State ex rel. 4
Bevacqua-Young v. Steele, 2017-NMCA-081, ¶ 9, 406 P.3d 547 (“In a de novo appeal 5
to the district court, there is a new trial on the entire case—that is, on both questions 6
of fact and issues of law—conducted as if there had been no trial in the first instance.” 7
(internal quotation marks and citation omitted)). In the de novo proceedings here, 8
Defendant filed numerous motions including a motion to dismiss for violation of the 9
Double Jeopardy Clause, the subject of this appeal. Because the district court was not 10
sitting in a typical appellate capacity, the district court was not bound by the 11
magistrate court’s decisions and was required to make an independent determination 12
of whether manifest necessity supported the magistrate court’s declaration of a 13
mistrial. See State v. Foster, 2003-NMCA-099, ¶¶ 9, 19, 134 N.M. 224, 75 P.3d 824 14
(holding that because the magistrate court is not a court of record, appeals from there 15
are heard de novo in district court, which required the district court to decide anew, 16
without deference to the magistrate court, whether a mistrial was warranted). The 17
district court, however, was bound by events that transpired in magistrate court and 18
therefore was required to base its independent judgment on the limited record brought 19
3
before it and the arguments made by counsel in district court. See id. ¶¶ 19-20; City 1
of Farmington v. Piñon-Garcia, 2013-NMSC-046, ¶ 12, 311 P.3d 446 (stating that the 2
history of a case in a court not of record is not disregarded when appealed to the 3
district court for a trial de novo). 4
{3} The State raises arguments in this case about Defendant’s failure to more fully 5
develop the record to establish error. It appears that, at least in the context of a 6
challenge in district court to a plea agreement entered into in magistrate court, the 7
district court is permitted to take evidence to clarify the limited record from magistrate 8
court. See State v. Gallegos, 2007-NMCA-112, ¶¶ 16, 18, 142 N.M. 447, 166 P.3d 9
1101 (explaining that the district court properly conducted an evidentiary hearing to 10
reconstruct the magistrate proceedings to allow it to fulfill its “obligation to determine 11
the validity of the plea in order to determine its jurisdiction over the appeal”). Our 12
Supreme Court has also explained that it is permissible for the district court to hold 13
a hearing to reconstruct the magistrate proceedings when asked to decide whether the 14
magistrate court acquitted the defendant on the merits or dismissed the complaint for 15
a procedural violation. See State v. Baca, 2015-NMSC-021, ¶¶ 2, 27, 352 P.3d 1151. 16
{4} In this case, the district court held a hearing on Defendant’s motion to dismiss 17
and relied on the limited magistrate court record and the parties’ stipulation to facts, 18
including the stipulation to the defense’s offer of proof, in order to clarify events in 19
4
magistrate court. There was no objection to this process. Also, neither the parties nor 1
the district court asked that the record be supplemented with testimony from the 2
magistrate judge to determine whether the magistrate judge considered less severe 3
alternatives to a mistrial. We therefore decline the State’s request to hold that it is a 4
defendant’s burden to re-create a complete record of the magistrate court proceedings. 5
See Rule 12-321(A) NMRA (“To preserve an issue for review, it must appear that a 6
ruling or decision by the trial court was fairly invoked.”). In this appeal, we simply 7
rely on the facts as they were presented to, and found by, the district court to review 8
whether the declaration of a mistrial was an abuse of discretion. See State v. Baca, 9
2015-NMSC-021, ¶ 25 (stating that we review double jeopardy claims de novo and 10
defer to the facts found by the district court, not the magistrate court, “because it was 11
the district court that had to find the facts on which to apply the law in ruling on the 12
motion to dismiss”); see also State v. Gutierrez, 2014-NMSC-031, ¶ 21, 333 P.3d 247 13
(noting that “manifest necessity mistrial rulings are reviewed for abuse of discretion”). 14
FACTUAL BACKGROUND 15
{5} Defendant was charged and tried in magistrate court for misdemeanor DWI and 16
failure to maintain his lane. The case was tried before eight jurors—six regular jurors 17
and two alternates. After the trial concluded and the jury was instructed on the law, 18
the magistrate court dismissed the two alternate jurors and excused the six-person jury 19
5
from the courtroom to deliberate. Approximately five minutes into deliberations, a 1
juror informed the magistrate judge by note that she could not be impartial based on 2
her personal and business dealings with Defendant’s family. The magistrate judge 3
walked into the courtroom, showed the note to the parties, and directed the parties to 4
discuss the note in chambers. Defense counsel immediately turned to his legal 5
assistant and instructed her to leave the courtroom to see if she could find the two 6
alternate jurors. Defense counsel accompanied his legal assistant and saw that the two 7
alternate jurors were still in the courthouse, standing in the lobby at a counter, doing 8
paperwork or waiting to do paperwork. Defense counsel immediately walked back to 9
chambers and asked the magistrate judge to call the alternate jurors back to determine 10
whether they could still serve as impartial jurors and replace the biased juror. The 11
State asked for a mistrial, and the defense objected. The magistrate judge rejected the 12
defense’s proposal without attempting to locate and question the alternate jurors, and 13
declared a mistrial. Thereafter, the magistrate court entered a written order declaring 14
a mistrial due to manifest necessity. 15
{6} After hearing the parties’ presentation of the facts and legal argument on the 16
events in magistrate court, the district court took the matter under advisement. The 17
district court also considered the parties’ briefs on the matter and entered a detailed 18
letter decision. The district court observed a lack of dispute that good cause existed 19
6
to dismiss the juror who expressed bias regarding Defendant and framed the question 1
as whether the magistrate court adequately inquired into alternatives to a mistrial. The 2
district court further observed that the absence of a record made it difficult to 3
determine whether alternatives to a mistrial were considered and acknowledged the 4
parties’ stipulation that the magistrate judge did not question the alternate jurors about 5
their ability to serve after they were released. On the facts presented to it, the district 6
court concluded that manifest necessity justified a mistrial, based on the district court 7
rule governing alternate jurors, i.e. Rule 5-605(B) and (C) NMRA, and on a Supreme 8
Court opinion holding that Rule 5-605 does not permit substitution of an alternate 9
juror after jury deliberations have begun. See State v. Sanchez, 2000-NMSC-021, ¶¶ 10
1, 23, 129 N.M. 284, 6 P.3d 486. Defendant appeals from this ruling. 11
DISCUSSION 12
{7} The Double Jeopardy Clause guarantees that no person shall be “twice put in 13
jeopardy” for the same offense. U.S. Const. amend. V; N.M. Const. art. II, § 15. 14
“However, the principles of double jeopardy do not prohibit retrying a defendant, even 15
over the defendant’s objections, after a mistrial that was justified by manifest 16
necessity.” State v. Desnoyers, 2002-NMSC-031, ¶ 33, 132 N.M. 756, 55 P.3d 968 17
(internal quotation marks and citation omitted), abrogated on other grounds as 18
recognized by State v. Rivas, 2017-NMSC-022, ¶ 47, 398 P.3d 299. The burden of 19
7
proving “manifest necessity” falls on the prosecutor, and the magnitude of that burden 1
is appropriately characterized by its very terms. Arizona v. Washington, 434 U.S. 497, 2
505 (1978). Two requirements must be met for an appellate court to uphold a mistrial 3
for manifest necessity. “First, the circumstances necessitating the mistrial must be 4
extraordinary ones, sufficient to override the defendant’s double jeopardy interests. 5
Second, the trial judge must determine whether an alternative measure—less drastic 6
than a mistrial—can alleviate the problem so that the trial can continue to an impartial 7
verdict.” State v. Yazzie, 2010-NMCA-028, ¶ 13, 147 N.M. 768, 228 P.3d 1188 8
(internal quotation marks and citation omitted). 9
{8} As indicated above, we review the trial court’s declaration of a mistrial for 10
abuse of discretion, which in this case is the standard we apply to the district court’s 11
de novo ruling. See Baca, 2015-NMSC-021, ¶ 25. The degree of deference and 12
scrutiny we accord the declaration of a mistrial under the abuse of discretion standard 13
depends on the reason for the mistrial. See Washington, 434 U.S. at 508-10 (providing 14
examples that fall within the continuum of appellate scrutiny and deference accorded 15
to mistrials); Gutierrez, 2014-NMSC-031, ¶ 22 (acknowledging that while abuse of 16
discretion is the appropriate standard of review for mistrials, the strictest scrutiny is 17
applied to mistrials ordered for missing prosecution witnesses). 18
8
{9} The parties in this case do not dispute that it was appropriate to remove the 1
deliberating juror who said she could not be impartial from the jury, which left only 2
five jurors. There also is no dispute that a jury in magistrate court must be comprised 3
of six jurors. See NMSA 1978, § 35-8-3(A) (1974); Rule 6-605(A). Thus, the dispute 4
is focused entirely on the second requirement for a finding of manifest 5
necessity—whether there was a less drastic alternative to a mistrial that would 6
“alleviate the problem so that the trial [could] continue to an impartial verdict.” 7
Yazzie, 2010-NMCA-028, ¶ 13 (internal quotation marks and citation omitted). 8
{10} Defendant argues that the district court’s ruling, relying on district court Rule 9
5-605, overlooks the fact that procedures in magistrate court differ from those in 10
district court. As Defendant points out, Rule 5-605(C) mandates that in a noncapital 11
case before the district court, “an alternate juror who does not replace a regular juror 12
shall be discharged before the jury retires to consider its verdict.” Id. The magistrate 13
court rules have no such requirement for the discharge of alternate jurors. Defendant 14
informs us that, unlike in district court, it is common practice in the Clovis Magistrate 15
Court for the judge to ask counsel whether they wish to retain the alternate jurors 16
during deliberations or release them. Defendant contends that the magistrate court 17
should have explored the possibility of replacing the biased juror with one of the 18
alternates and refers this Court to several federal cases that permit, in the absence of 19
9
prejudice to the defendant, the substitution of an alternate juror who had been 1
dismissed when the case was submitted to the jury for deliberation—the practice is 2
called “post-submission substitution.” 3
{11} We agree with Defendant that generally the magistrate court is not required to 4
follow a district court rule in the absence of a similar magistrate court rule, and we 5
further acknowledge that, typically, the district court is required to apply the rules of 6
the magistrate court when considering issues in de novo proceedings. See State v. 7
Sharp, 2012-NMCA-042, ¶ 8, 276 P.3d 969 (emphasizing that, in de novo 8
proceedings, the district court is required to apply the rules of the lower, non-record 9
court in its independent consideration of an issue decided below). Under the 10
circumstances, however, we are not persuaded that the district court erred by relying 11
on the district court rule and New Mexico case law governing the discharge of 12
alternate jurors. 13
{12} Even assuming that the magistrate court usually gives the parties the option of 14
retaining alternate jurors during deliberations, and assuming that this is permitted in 15
New Mexico, the parties in the current case agreed that the alternate jurors could be 16
excused. There is no indication that the magistrate court advised the alternate jurors 17
that they continued to be bound by their oath and obligations as alternate jurors when 18
it discharged them. Thus, the alternate jurors were discharged from jury duty, left the 19
10
courtroom, and were present in the courthouse lobby. See State v. Rodriguez, 1
2006-NMSC-018, ¶ 7, 139 N.M. 450, 134 P.3d 737 (recognizing a presumption of 2
prejudice “once a juror has left the presence and control of the court into an area 3
occupied by the general public”). The magistrate court rules contain no provisions for 4
the use of alternate jurors or the discharge of jurors. While nothing in the magistrate 5
court rules mandates the use of district court rules, we cannot say it was error for the 6
magistrate court to use the rules adopted for district courts in New Mexico as guidance 7
in this situation. Cf. State v. Romero, 2014-NMCA-063, ¶¶ 6-8, 327 P.3d 525 (finding 8
guidance, where logical, in civil procedure on a matter where the Rules of Criminal 9
Procedure were silent). 10
{13} Furthermore, our Supreme Court has declared by rule and case law that the New 11
Mexico policy governing alternate jurors does not authorize post-submission 12
substitution of jurors. Sanchez, 2000-NMSC-021, ¶ 21 (“In the absence of a rule 13
authorizing post-submission substitution, however, we interpret our rule as not 14
authorizing post-submission substitution.”). Our Supreme Court considered the 15
approach Defendant advocates in this case and determined that such an approach was 16
rejected in our state by the absence of a rule authorizing it. Id. ¶¶ 21-23. Although our 17
Supreme Court felt bound by the restrictive language of Rule 5-605, it acknowledged 18
that some changes to the rule may be constitutionally permissible and invited future 19
11
consideration of changes to it. Id. ¶ 21 (“We are not at liberty, in a decisional context, 1
to change the language of our rule. If there is to be a change in the rule or the policy 2
underlying the rule, it must come through the normal rule-making process.”(alteration, 3
omissions, internal quotation marks, and citation omitted)). Our Supreme Court, 4
however, has not altered Rule 5-605 since the opinion in Sanchez was published in 5
2000. Sanchez then states the prevailing view in New Mexico that a “post-submission 6
substitution is error under Rule 5-605; it is error that creates a presumption of 7
prejudice; the state must show under the circumstances . . . that the trial court took 8
adequate steps to ensure the integrity of the jury process.” Id. ¶ 23. 9
{14} We have no case law deciding whether, under any circumstances, it was an 10
abuse of discretion to declare a mistrial based on a refusal to make a post-submission 11
substitution in the jury after the alternate jurors were dismissed. Cf. State v. Sanchez, 12
1995-NMSC-053, ¶ 16, 120 N.M. 247, 901 P.2d 178 (holding that the district court 13
did not abuse its discretion by denying the defendants’ motion for a retrial and 14
refusing the defendants’ request to replace a juror “with an alternate juror after the 15
jury had retired to deliberate, and the alternate jurors had been dismissed for more 16
than one day[,]” where the defendants were aware from voir dire of the juror’s 17
relationship to an employee for the prosecution).We conclude that a higher degree of 18
deference is appropriate when the court’s refusal to make a post-submission 19
12
substitution, after alternate jurors were already dismissed, resulted in a mistrial given 1
our Supreme Court’s prevailing view that a post-submission substitution is error that 2
creates a presumption of prejudice. 3
{15} In this case, not only were the alternate jurors discharged and present in a public 4
place, the deliberating juror Defendant sought to replace was removed, not for illness 5
or another case-neutral emergency, but for a late disclosure of bias. See Washington, 6
434 U.S. at 513 (“There are compelling institutional considerations militating in favor 7
of appellate deference to the trial judge’s evaluation of the significance of possible 8
juror bias.”); State v. Saavedra, 1988-NMSC-100, ¶ 9, 108 N.M. 38, 766 P.2d 298 9
(stating that where “the underlying issue involves a deadlocked jury or possible jury 10
bias, the trial judge should be allowed broad discretion whether to declare a mistrial”); 11
cf. Sanchez, 2000-NMSC-021, ¶¶ 4, 9, 13, 16 (cataloging cases across the country 12
involving post-submission substitution where a deliberating juror became disabled, 13
ill, or incapacitated, and holding that the district court erred by making a post- 14
submission substitution where the district court failed to take adequate precautions to 15
protect the deliberative process, where a deliberating juror was discharged for illness). 16
{16} Although the timing of the biased juror’s disclosure was only five minutes into 17
deliberations, Defendant’s own proffer in district court to present testimony from one 18
of the other deliberating jurors demonstrates that five minutes is not an insignificant 19
13
time to deliberate; rather, it can be adequate time for jurors to reach certain 1
conclusions. Indeed, Defendant asserted in the district court that “[t]he jury was five 2
(5) to one (1) for acquittal.” Our case law has long recognized that, generally, “a lone 3
biased juror undermines the impartiality of an entire jury[.]” State v. Gallegos, 2009- 4
NMSC-017, ¶ 22, 146 N.M. 88, 206 P.3d 993 (internal quotation marks and citation 5
omitted). We agree with the State that the timing of the juror’s confession of 6
bias—after hearing the entire trial and having been excused to deliberate with the jury 7
for even five minutes—gives rise to grave concerns that the juror’s bias could have 8
tainted or contaminated the remaining jurors. See State v. Mann, 2002-NMSC-001, 9
¶ 27, 131 N.M. 459, 39 P.3d 124 (“Jury tampering and juror bias present the clearest 10
examples of potentially improper influences upon a jury[.]”); cf. Gallegos, 11
2009-NMSC-017, ¶ 23 (holding that a mistrial was not warranted given the early stage 12
of the trial, the absence of a claim that there were improper communications among 13
the jurors suggesting bias, the discreet manner in which the biased juror alerted the 14
judge, and the early replacement of the juror with an alternate). The Supreme Court 15
of the United States has stated that “[n]either party has a right to have his case decided 16
by a jury which may be tainted by bias; in these circumstances, the public’s interest 17
in fair trials designed to end in just judgements must prevail over the defendant’s 18
valued right to have his trial concluded before the first jury impaneled.” Washington, 19
14
434 U.S. at 516 (internal quotation marks and citation omitted). This Court also has 1
acknowledged that “where the irregularity involves possible partiality within the jury, 2
it has been more often held that the public interest in fair verdicts outweighs [the] 3
defendant’s interest in obtaining a verdict by his first choice of jury.” State v. C. De 4
Baca, 1975-NMCA-120, ¶ 8, 88 N.M. 454, 541 P.2d 634. 5
{17} We recognize that the limited record available does not disclose the extent to 6
which the magistrate court considered less drastic alternative measures to a mistrial, 7
and we recognize that our case law requires some duty to inquire into those 8
alternatives, but it is “ ‘not clear as to what kind or how much of an inquiry into 9
alternatives is necessary.’ ” State v. Salazar, 1997-NMCA-088, ¶ 14, 124 N.M. 23, 10
946 P.2d 227 (alteration omitted) (quoting C. De Baca, 1975-NMCA-120, ¶ 10). 11
Nonetheless, we are not persuaded that, where faced with this risk of jury 12
contamination, the trial court was required to explore the proposed alternative to a 13
mistrial—a post-submission substitution—which itself would have created a 14
presumption of prejudice and would not have alleviated or even addressed the 15
potential taint to the remaining jurors. See Yazzie, 2010-NMCA-028, ¶ 13 (explaining 16
that the second requirement for manifest necessity requires the trial judge to 17
“determine whether an alternative measure—less drastic than a mistrial—can alleviate 18
the problem so that the trial can continue to an impartial verdict” (internal quotation 19
15
marks and citation omitted)). We have said that the proposed alternatives to a mistrial 1
must be feasible or reasonable. See State v. Messier, 1984-NMCA-085, ¶¶ 13-14, 101 2
N.M. 582, 686 P.2d 272. Where the proposed alternative to a mistrial carries a 3
likelihood of reversal, that alternative would not be reasonable. 4
{18} We will not hold that it was an abuse of discretion, after the disclosure of a 5
deliberating juror’s bias, for the magistrate court to refuse a measure that would 6
violate our only rule governing the discharge of alternate jurors in criminal trials and 7
would also result in presumptive prejudice. See Washington, 434 U.S. at 500-02, 513 8
(explaining that the absence of an express finding from the trial court that alternatives 9
to a mistrial were considered does not prevent a court from affording great deference 10
to a trial judge’s assessment of the potential bias of a jury); Sanchez, 2000-NMSC- 11
021, ¶¶ 21-23. We agree with the district court and hold that the mistrial was justified 12
by manifest necessity. See Saavedra, 1988-NMSC-100, ¶ 16 (concluding that where 13
there are “sufficient reasons presented to justify declaration of a mistrial, . . . the fact 14
that the judge would have been in a better position to assess the situation had he taken 15
the steps suggested by the defendant” does not preclude an affirmance of manifest 16
necessity for a mistrial). 17
CONCLUSION 18
10
11
2
13
the steps suggested by the defendant” does not preclude an affirmance of manifest
necessity for a mistrial).
CONCLUSION
{19} Based on the foregoing, we affirm the district court’s denial of Defendant’s
motion to dismiss for violation of the Double Jeopardy Clause.
20 ITISSO ORDERED.
PVE
EMIL J. KIEHNE, Judge
WE CONCUR:
Ly
MICHAEIAE. VIGIL, Judge
Al... / Set
HENRY M. BOHNHOFF, Judge
16Was bedeutet dieser Text für Ihre Situation?
Kostenlose und unverbindliche Beratung
Schildern Sie uns Ihre Situation. Unser Team meldet sich per E-Mail bei Ihnen für Ihre Beratung.
Setzen Sie Ihre Recherche in ChatGPT oder Claude fort
Verbinden Sie Omnilex, um den Rechtskorpus über Ihren KI-Assistenten zu durchsuchen.