case announces a new rule (New Mexico) · Go Syfert
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case announces a new rule in New Mexico

9 New Mexico opinions name it 2 courts 2000–2021 1 in the last five years

The cases below were cited by New Mexico courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Kersey v. Hatchgreen
nm · 2010 · cited in 5 New Mexico opinions naming this issue, 2012–2021
2 sentences

2021Stated differently, “a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final” or when an appellate court’s “decision is flatly inconsistent with the prior governing precedent and is an explicit overruling of an earlier holding.” Id. (internal quotation marks and citations omitted). {12} In Muqqddin, the Court explained that existing precedent regarding burglary of a vehicle wrongly expanded the scope of what could constitute the “prohibited space” of a vehicle under the burglary statute. 2012-NMSC-029, ¶¶ 1, 22-23, 32

2020To put it differently, a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.” 2010-NMSC-020, ¶ 16 (internal quotation marks and citation omitted).

35
Teague v. Lanegreen
scotus · 1989 · cited in 5 New Mexico opinions naming this issue, 2000–2021
2 sentences

2021See 2012-NMSC-029, ¶¶ 36-38 ; see also Teague, 489 U.S. at 301 (stating that “a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final”).

2017The Teague Court determined that “a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.” 489 U.S. at 301 (emphasis omitted).

35
State v. Kirbygreen
nm · 1996 · cited in 2 New Mexico opinions naming this issue, 2000–2000
2 sentences

2000See Kirby, 1996-NMSC-069, ¶5 , 122 N.M. 609 , 930 P.2d 144 .

2000See Kirby, 1996-NMSC-069, ¶5 , 122 N.M. 609 , 930 P.2d 144 .

22
State v. Office of the Public Defender Ex Rel. Muqqddingreen
nm · 2012 · cited in 1 New Mexico opinions naming this issue, 2021–2021
2 sentences

2021Stated differently, “a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final” or when an appellate court’s “decision is flatly inconsistent with the prior governing precedent and is an explicit overruling of an earlier holding.” Id. (internal quotation marks and citations omitted). {12} In Muqqddin, the Court explained that existing precedent regarding burglary of a vehicle wrongly expanded the scope of what could constitute the “prohibited space” of a vehicle under the burglary statute. 2012-NMSC-029, ¶¶ 1, 22-23, 32

2021See 2012-NMSC-029, ¶¶ 36-38 ; see also Teague, 489 U.S. at 301 (stating that “a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final”).

11
State v. Frawleyred
nm · 2007 · cited in 1 New Mexico opinions naming this issue, 2010–2010
2 sentences

2010To put it differently, a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.’ ” Mascarenas, 2000-NMSC-017 , ¶ 24, 129 N.M. 230 , 4 P.3d 1221 (quoting Teague, 489 U.S. at 301 , 109 S.Ct. 1060 ); see also State v. Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (same); State v. Forbes, 2005-NMSC-027, ¶ 7 , 138 N.M. 264 , 119 P.3d 144 (same).

2010To put it differently, a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.’ ” Mascarenas, 2000-NMSC-017 , ¶ 24, 129 N.M. 230 , 4 P.3d 1221 (quoting Teague, 489 U.S. at 301 , 109 S.Ct. 1060 ); see also State v. Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (same); State v. Forbes, 2005-NMSC-027, ¶ 7 , 138 N.M. 264 , 119 P.3d 144 (same).

11
State v. Ulibarrigreen
nmctapp · 1999 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005See State v. Ulibarri, 1999-NMCA-142 , ¶ 22, 128 N.M. 546 , 994 P.2d 1164 , aff'd, 2000-NMSC-007 , 128 N.M. 686 , 997 P.2d 818 , In Mascarenas, we recognized the difficulty of determining when a case announces a new rule but looked to Teague v. Lane, 489 U.S. 288 , 109 S.Ct. 1060 , 103 L.Ed.2d 334 (1989), for guidance: [W]e do not attempt to define the spectrum of what may or may not constitute a new rule for retroactivity purposes.

2005See State v. Ulibarri, 1999-NMCA-142 , ¶ 22, 128 N.M. 546 , 994 P.2d 1164 , aff'd, 2000-NMSC-007 , 128 N.M. 686 , 997 P.2d 818 , In Mascarenas, we recognized the difficulty of determining when a case announces a new rule but looked to Teague v. Lane, 489 U.S. 288 , 109 S.Ct. 1060 , 103 L.Ed.2d 334 (1989), for guidance: [W]e do not attempt to define the spectrum of what may or may not constitute a new rule for retroactivity purposes.

11
State v. Ulibarrigreen
nm · 2000 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005See State v. Ulibarri, 1999-NMCA-142 , ¶ 22, 128 N.M. 546 , 994 P.2d 1164 , aff'd, 2000-NMSC-007 , 128 N.M. 686 , 997 P.2d 818 , In Mascarenas, we recognized the difficulty of determining when a case announces a new rule but looked to Teague v. Lane, 489 U.S. 288 , 109 S.Ct. 1060 , 103 L.Ed.2d 334 (1989), for guidance: [W]e do not attempt to define the spectrum of what may or may not constitute a new rule for retroactivity purposes.

2005See State v. Ulibarri, 1999-NMCA-142 , ¶ 22, 128 N.M. 546 , 994 P.2d 1164 , aff'd, 2000-NMSC-007 , 128 N.M. 686 , 997 P.2d 818 , In Mascarenas, we recognized the difficulty of determining when a case announces a new rule but looked to Teague v. Lane, 489 U.S. 288 , 109 S.Ct. 1060 , 103 L.Ed.2d 334 (1989), for guidance: [W]e do not attempt to define the spectrum of what may or may not constitute a new rule for retroactivity purposes.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
State v. Mascarenas green
nm · 2000
2 sentences

2010To put it differently, a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.’ ” Mascarenas, 2000-NMSC-017 , ¶ 24, 129 N.M. 230 , 4 P.3d 1221 (quoting Teague, 489 U.S. at 301 , 109 S.Ct. 1060 ); see also State v. Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (same); State v. Forbes, 2005-NMSC-027, ¶ 7 , 138 N.M. 264 , 119 P.3d 144 (same).

2010To put it differently, a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.’ ” Mascarenas, 2000-NMSC-017 , ¶ 24, 129 N.M. 230 , 4 P.3d 1221 (quoting Teague, 489 U.S. at 301 , 109 S.Ct. 1060 ); see also State v. Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (same); State v. Forbes, 2005-NMSC-027, ¶ 7 , 138 N.M. 264 , 119 P.3d 144 (same).

22005–2010
State v. Nunez green
nm · 1999
2 sentences

2017The new rule “applies to cases pending on direct appeal, as long as the issue was raised and preserved below . . . .” Kersey, 2010-NMSC-020, ¶ 19 (citing State v. Nunez, 2000-NMSC-013 , ¶ 114, 129 N.M. 63 , 2 P.3d 264 ).

2017The new rule “applies to cases pending on direct appeal, as long as the issue was raised and preserved below . . . .” Kersey, 2010-NMSC-020, ¶ 19 (citing State v. Nunez, 2000-NMSC-013 , ¶ 114, 129 N.M. 63 , 2 P.3d 264 ).

12017–2017
Whorton v. Bockting green
scotus · 2007
2 sentences

2010Thus, “a court establishes a new rule when its decision is ‘flatly inconsistent with the prior governing precedent’ and is an ‘explicit overruling of an earlier holding.’” Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (quoting Whorton v. Bockting, 549 U.S. 406, 416 , 127 S.Ct. 1173 , 167 L.Ed.2d 1 (2007)). {17} We conclude that Frazier announced a new rule because it was flatly inconsistent with our precedent governing multiple convictions for felony murder and the predicate felony.

2010Thus, “a court establishes a new rule when its decision is ‘flatly inconsistent with the prior governing precedent’ and is an ‘explicit overruling of an earlier holding.’” Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (quoting Whorton v. Bockting, 549 U.S. 406, 416 , 127 S.Ct. 1173 , 167 L.Ed.2d 1 (2007)). {17} We conclude that Frazier announced a new rule because it was flatly inconsistent with our precedent governing multiple convictions for felony murder and the predicate felony.

12010–2010
State v. Forbes green
nm · 2005
2 sentences

2010To put it differently, a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.’ ” Mascarenas, 2000-NMSC-017 , ¶ 24, 129 N.M. 230 , 4 P.3d 1221 (quoting Teague, 489 U.S. at 301 , 109 S.Ct. 1060 ); see also State v. Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (same); State v. Forbes, 2005-NMSC-027, ¶ 7 , 138 N.M. 264 , 119 P.3d 144 (same).

2010To put it differently, a case announces a new rule if the result was not dictated by precedent existing at the time the defendant’s conviction became final.’ ” Mascarenas, 2000-NMSC-017 , ¶ 24, 129 N.M. 230 , 4 P.3d 1221 (quoting Teague, 489 U.S. at 301 , 109 S.Ct. 1060 ); see also State v. Frawley, 2007-NMSC-057, ¶ 35 , 143 N.M. 7 , 172 P.3d 144 (same); State v. Forbes, 2005-NMSC-027, ¶ 7 , 138 N.M. 264 , 119 P.3d 144 (same).

12010–2010

Where else courts name it

IL 35 (1990–2021) TN 17 (1993–2019) NJ 9 (1996–2019) MA 9 (1990–2025) NM 9 (2000–2021) TX 9 (2013–2024) CA 7 (2007–2025) NY 7 (1995–2016) PA 7 (1999–2020) IN 7 (1997–2011) MI 6 (1998–2026) MN 5 (2015–2025) OH 4 (2005–2025) RI 4 (1992–2019) WI 4 (1991–2004) ID 4 (2015–2023) LA 3 (1992–1997) MD 3 (2012–2014) CO 3 (2006–2024) CT 3 (2011–2016) HI 3 (2015–2018) WA 3 (2015–2015) IA 3 (1991–2022) GA 3 (2004–2016) ND 2 (2018–2018) VT 2 (2017–2018) WY 2 (2014–2014) AZ 2 (2003–2003) ME 2 (2002–2010) MS 2 (2009–2013) SC 2 (2007–2015) FL 2 (2004–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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