In State v. Largo, the defendant was convicted of first-degree murder and tampering with evidence after shooting his ex-girlfriend, who identified him as the shooter in statements relayed during a 911 call and to a responding deputy before she died from her wounds. The New Mexico Supreme Court affirmed the convictions, holding that the victim's out-of-court statements were nontestimonial under the context-specific inquiry from Michigan v. Bryant because they were made amid an ongoing emergency rather than primarily to aid prosecution, and thus did not violate the Confrontation Clause. The court further ruled the statements admissible under the dying declaration hearsay exception and found sufficient evidence of deliberation, including the number of shots fired and the defendant's post-incident behavior, to support the first-degree murder conviction.
The case concerned whether the City of Albuquerque's Labor-Management Relations Ordinance provision for appointing an interim neutral member to its local labor board, via the City Council President, satisfied the grandfather clause of the state Public Employee Bargaining Act. The underlying dispute involved a union's prohibited practices complaint against the City that had deadlocked at the local board level after the neutral member recused, leading the state Public Employee Labor Relations Board to assert jurisdiction. The New Mexico Supreme Court held that the local ordinance qualified for grandfathering and that the state board lacked jurisdiction. The core reasoning was that the City Council President does not act in a management or labor capacity, so the appointment process preserves the required neutral character of the board and aligns with the Act's definition of collective bargaining.
The case involved members of the New Mexico Legislature challenging the Governor's partial veto of a $150,000 appropriation in the 2011 General Appropriation Act, which she reduced to $50,000 by striking the digit '1' from the amount designated for the Department of Finance and Administration to support the New Mexico mortgage finance authority under regional housing law. The Supreme Court of New Mexico granted a writ of mandamus and held that the Governor's partial veto was invalid and unconstitutional. The court's reasoning centered on the state constitution's separation of powers, which vests exclusive authority to appropriate funds in the Legislature under Articles IV, Sections 16 and 30, while limiting the Governor's veto power under Article IV, Section 22 to approving or disapproving entire items or parts without authority to scale down or modify the amount of an appropriation.
The case involved a loss-of-consortium claim brought by Bill Wachocki, the adult brother of Jason Wachocki, who was killed when his vehicle was struck by a van driven by a Bernalillo County corrections officer. The New Mexico Supreme Court addressed whether recovery for loss of consortium could extend to sibling relationships and whether the brothers' relationship satisfied the required standard. The court clarified that such claims are available to siblings when the relationship exhibits mutual dependence, based on factors like shared household, financial responsibilities, and emotional reliance, but determined that the brothers' situation as roommates who split bills and chores did not meet this threshold. The court therefore affirmed the denial of the claim while upholding the underlying wrongful death action.
The case was a wrongful death suit filed in state court by the representatives of two siblings killed in a car accident after being served alcohol at a tribal casino despite visible intoxication, alleging violations of tribal liquor ordinances. The New Mexico Supreme Court held that state courts have jurisdiction under Section 8 of the Tribal-State Class III Gaming Compact, which consents to state court suits for personal injuries caused by casino conduct, overriding any exclusive tribal court provisions in the liquor ordinance. The court further decided that the state Liquor Control Act does not preempt common law dram shop claims against non-licensee taverns such as the casino, recognizing third-party claims based on ordinary negligence and patron claims requiring proof of gross negligence.
The case involved TW Telecom's appeal of a final order by the New Mexico Public Regulation Commission (PRC) establishing an alternative form of regulation plan (AFOR III) for Qwest Corporation's rates and services. TW Telecom argued that the PRC improperly incorporated conclusions and evidence from a prior Competitive Response Case into the AFOR III order without allowing parties in the current proceeding an opportunity to present evidence or cross-examine witnesses on those points, violating due process. The New Mexico Supreme Court held that the PRC's decision was not based solely on the AFOR III record and that TW Telecom was denied a meaningful chance to be heard regarding the adoption of the prior ruling. The court annulled and vacated the AFOR III Final Order and remanded the matter to the PRC for further proceedings to afford all parties the opportunity to address the relevant issues with evidence.