The case concerned consolidated challenges to the constitutionality of New Mexico's 1973 death penalty statute under the Eighth and Fourteenth Amendments to the U.S. Constitution and parallel provisions of the New Mexico Constitution. A lower court had ruled the statute invalid under Furman v. Georgia and held that life imprisonment would be the maximum penalty for first-degree murder. The New Mexico Supreme Court exercised its superintending control to resolve the issue statewide. It held that capital punishment does not constitute cruel and unusual punishment per se, reasoning that the U.S. Constitution expressly contemplates the death penalty in multiple clauses, that it was a recognized punishment at the time of the founding, and that no controlling precedent had declared it inherently unconstitutional.
In State v. DeSantos, the defendant was convicted of first degree murder after a jury trial on an open charge and appealed on multiple grounds, including the constitutionality of the death penalty statute, admission of evidence, prosecutorial comments, and jury instructions. The court upheld the constitutionality of the relevant statutes, found no error in the admission of photographs or other claims, and affirmed a separate conviction for unlawful taking of a vehicle, but reversed the murder conviction and remanded for a new trial. The core reasoning was that the trial court improperly instructed the jury on theories of felony murder and depraved mind murder without supporting evidence, while also giving overlapping and confusing instructions on premeditated murder theories, which injected an intolerable level of confusion into the verdict. The court viewed the evidence in the light most favorable to the state but concluded there was not substantial evidence to support all instructed theories.
The case concerned a subdivision developer's request for a writ of mandamus to compel the Santa Fe County Board of Commissioners to approve all submitted plats for a residential subdivision that complied with state statutes and county regulations. The Board had approved the plats in stages, conditioning further approvals on the sale or development of previously approved lots. The court analyzed whether the Board had a clear legal duty to approve the plats or if approval involved discretionary authority, referencing statutory provisions that set minimum requirements but allow for some commission judgment.
This case involved a negligence action by plaintiff Montanez, an electrician's helper injured when he contacted a live wire while dismantling a secondary electrical system at an oil well. The trial court granted summary judgment to all defendants (Utility, Cass the installer, and Wolfson the owner), but the New Mexico Supreme Court affirmed in part and reversed in part. It held that summary judgment for the Utility was proper because the Utility had no duty to inspect or liability for a secondary system it did not install or control and of which it lacked actual knowledge of defects. Summary judgment for Wolfson was also proper as the owner of property who hired an independent contractor without retaining control over the work. However, the court reversed summary judgment for Cass, finding a genuine issue of fact regarding whether Montanez reasonably relied on statements that lines were de-energized, and held that Cass owed a duty of care; it also ruled that contributory negligence issues must go to the jury.
This case involves a post-divorce dispute in which the husband sought a change of custody of one child from his former wife, who counterclaimed for contempt regarding unpaid alimony and child support arrears under their 1972 Missouri divorce decree. The trial court ordered a change of custody for one child, reduced future alimony and child support, and required only partial payment of the delinquent alimony. The New Mexico Supreme Court reversed in part, holding that the trial court erred by failing to award full judgments for the alimony and child support arrearages and by modifying future alimony, while affirming the custody change, the modification of future child support, the handling of the contempt claim, and the denial of attorney fees. The core reasoning was that the Missouri decree was entitled to full faith and credit under the U.S. Constitution, Missouri law did not permit retroactive modification of accrued support obligations, and the equitable contempt proceeding allowed the trial court discretion over punishment and related future adjustments.
This case involves a wrongful death tort claim brought by the administrator of an employee injured on the job against his employer. The trial court dismissed the claim with prejudice, ruling that the employer's substantial compliance with the Workmen’s Compensation Act barred the common law tort action. The Court of Appeals reversed, and the New Mexico Supreme Court affirmed that reversal. The court held that the employer had not substantially complied with the Act's requirements to file insurance policy documentation or other security with the district court clerk, as nothing was filed despite the existence of a policy, and therefore the tort claim could proceed. The core reasoning was that New Mexico precedent requires substantial (though not strict) compliance with the statutory filing provisions to foreclose an employee's common law remedies.