reasonable doubt standard (New Mexico) · Go Syfert
← New Mexico issues

reasonable doubt standard in New Mexico

53 New Mexico opinions name it 2 courts 1947–2025 5 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 (39)

CaseFollowedCited
State v. Tollardogreen
nm · 2012 · cited in 3 New Mexico opinions naming this issue, 2013–2018
2 sentences

2018The State has the burden on appeal to "establish[ ] beyond a reasonable doubt that the jury verdict was not tainted by the constitutional error." Gutierrez , 2007-NMSC-033 , ¶ 18, 142 N.M. 1 , 162 P.3d 156 ; see also Tollardo , 2012-NMSC-008 , ¶ 36, 275 P.3d 110 ("[T]he reasonable possibility standard continues to *540 resemble the reasonable doubt standard[.]" (internal quotation marks and citation omitted) ).

2018The State has the burden on appeal to "establish[ ] beyond a reasonable doubt that the jury verdict was not tainted by the constitutional error." Gutierrez , 2007-NMSC-033 , ¶ 18, 142 N.M. 1 , 162 P.3d 156 ; see also Tollardo , 2012-NMSC-008 , ¶ 36, 275 P.3d 110 ("[T]he reasonable possibility standard continues to *540 resemble the reasonable doubt standard[.]" (internal quotation marks and citation omitted) ).

33
Apprendi v. New Jerseygreen
scotus · 2000 · cited in 4 New Mexico opinions naming this issue, 2005–2009
2 sentences

2009See State v. Bullcoming, 17 2008-NMCA-097, ¶¶ 25-27 , 144 N.M. 546 , 189 P.3d 679 (holding that neither 18 Apprendi v. New Jersey, 530 U.S. 466 (2000), nor its progeny require prior 3 1 convictions to be proved beyond a reasonable doubt and concluding that the “beyond 2 a reasonable doubt standard does not apply to a finding of a prior DWI conviction for 3 purposes of DWI sentencing”), cert. granted, 2008-NMCERT-007 , 144 N.M. 594 , 4 189 P.3d 1216 . 5 For the reasons stated in this opinion and in the notice of proposed summary 6 disposition, we affirm. 7 IT IS SO ORDERED. 8 __________________

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

24
State v. Alvarez-Lopezgreen
nm · 2004 · cited in 3 New Mexico opinions naming this issue, 2007–2009
2 sentences

2009In Alvarez-Lopez, our Supreme Court noted Fulminante in which the United States Supreme Court “was faced with determining whether a criminal defendant’s involuntary confession, which was unconstitutionally admitted into evidence against him at his trial, contributed to his conviction.” Alvarez-Lopez, 2004-NMSC-030, ¶ 34 , 136 N.M. 309 , 98 P.3d 699 .

2009In Alvarez-Lopez, our Supreme Court noted Fulminante in which the United States Supreme Court “was faced with determining whether a criminal defendant’s involuntary confession, which was unconstitutionally admitted into evidence against him at his trial, contributed to his conviction.” Alvarez-Lopez, 2004-NMSC-030, ¶ 34 , 136 N.M. 309 , 98 P.3d 699 .

23
State Ex Rel. CYFD v. Maisie Y.green
nmctapp · 2021 · cited in 2 New Mexico opinions naming this issue, 2022–2022
2 sentences

2022See Maisie Y., 2021-NMCA-023, ¶ 19 (“[W]e hold that Section 32A- 14 4-29(I) dictates the grounds supporting termination of parental rights in ICWA cases, 15 including the determination that a child has been abused or neglected under Section 16 32A-4-28(B)(2), must be proved beyond a reasonable doubt.”). 17 {15} In this case, the district court properly found neglect by Father under Section 18 32A-4-2(G)(2) at the adjudicatory hearing, applying the clear and convincing 19 evidence standard of proof, and in contrast, made its finding of neglect at the TPR 6 1 hearing by evidence beyond a reasona

2022See Maisie Y., 2021-NMCA-023, ¶ 19 (“[W]e hold that Section 32A-4-29(I) dictates the grounds supporting termination of parental rights in ICWA cases, including the determination that a child has been abused or neglected under Section 32A-4-28(B)(2), must be proved beyond a reasonable doubt.”). {15} In this case, the district court properly found neglect by Father under Section 32A-4-2(G)(2) at the adjudicatory hearing, applying the clear and convincing evidence standard of proof, and in contrast, made its finding of neglect at the TPR hearing by evidence beyond a reasonable doubt. 3 We do not

22
State v. Raelgreen
nmctapp · 2008 · cited in 2 New Mexico opinions naming this issue, 2015–2016
2 sentences

2016Rael, 10 2008-NMCA-067, ¶ 22 (“[I]f a requirement of reasonable doubt were not read into 11 Rule 5-602(B)(2)(b), any defendant would be able to raise the issue of competency 12 and have the jury decide it even in the absence of the slightest bit of evidence that the 13 defendant was incompetent.

2015See Rael, 2008-NMCA-067, ¶ 22 (holding 2 that the reasonable doubt requirement “is implied” under Rule 5-602(B)(2)(b) when 3 the issue of competency is re-raised at trial). 4 Prosecutorial Misconduct 5 {18} Defendant next argues that prosecutorial misconduct at closing argument 6 requires reversal.

22
State v. Garciagreen
nm · 1992 · cited in 2 New Mexico opinions naming this issue, 2001–2007
2 sentences

2007State v. Garcia, 114 N.M. 269, 274 , 837 P.2d 862, 867 (1992) (noting that Jackson requires consideration of beyond a reasonable doubt standard in determining sufficiency of evidence in criminal case); see also 2A Charles Alan Wright, Federal Practice and Procedure: Criminal § 467 (3d. ed.2000) (noting minimal support for proposition that standard for sufficiency of evidence is same in civil and criminal cases and ultimate rejection of this view by Supreme Court in Jackson).

2007State v. Garcia, 114 N.M. 269, 274 , 837 P.2d 862, 867 (1992) (noting that Jackson requires consideration of beyond a reasonable doubt standard in determining sufficiency of evidence in criminal case); see also 2A Charles Alan Wright, Federal Practice and Procedure: Criminal § 467 (3d. ed.2000) (noting minimal support for proposition that standard for sufficiency of evidence is same in civil and criminal cases and ultimate rejection of this view by Supreme Court in Jackson).

22
State v. Waltersgreen
nmctapp · 2006 · cited in 2 New Mexico opinions naming this issue, 2007–2007
2 sentences

2007Johnson, 2004-NMSC-029, ¶ 9 ; see also Alvarez-Lopez, 2004-NMSC-030, ¶ 25 . {20} “In determining whether the error was harmless, we must be able to conclude beyond a reasonable doubt that the jury verdict would have been the same in the absence of the error by looking to the effect that the constitutional error had upon the guilty verdict in this particular case.” See State v. Walters, 2006-NMCA-071, ¶ 39 , 139 N.M. 705 , 137 P.3d 645 , cert. granted, 2006-NMCERT-006 , 140 N.M. 226 , 141 P.3d 1280 .

2007Johnson, 2004-NMSC-029, ¶ 9 ; see also Alvarez-Lopez, 2004-NMSC-030, ¶ 25 . {20} “In determining whether the error was harmless, we must be able to conclude beyond a reasonable doubt that the jury verdict would have been the same in the absence of the error by looking to the effect that the constitutional error had upon the guilty verdict in this particular case.” See State v. Walters, 2006-NMCA-071, ¶ 39 , 139 N.M. 705 , 137 P.3d 645 , cert. granted, 2006-NMCERT-006 , 140 N.M. 226 , 141 P.3d 1280 .

22
Oken v. Stategreen
md · 2003 · cited in 2 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

2005As the Supreme Court held in Booker, Apprendi's requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. "[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

22
Commonwealth v. Roneygreen
pa · 2005 · cited in 2 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

22
State v. Trujillogreen
nm · 1981 · cited in 2 New Mexico opinions naming this issue, 1983–1991
2 sentences

1991See State v. Trujillo, 95 N.M. 535 , 624 P.2d 44 (1981); State v. Dobbs, 100 N.M. 60, 67 , 665 P.2d 1151, 1158 (Ct.App. 1983) (citing Chapman v. California, 386 U.S. 18 , 87 S.Ct. *885 824, 17 L.Ed.2d 705 (1967)); State v. Bell, 90 N.M. 160 , 560 P.2d 951 (Ct.App. 1977).

1991See State v. Trujillo, 95 N.M. 535 , 624 P.2d 44 (1981); State v. Dobbs, 100 N.M. 60, 67 , 665 P.2d 1151, 1158 (Ct.App. 1983) (citing Chapman v. California, 386 U.S. 18 , 87 S.Ct. *885 824, 17 L.Ed.2d 705 (1967)); State v. Bell, 90 N.M. 160 , 560 P.2d 951 (Ct.App. 1977).

22
State v. Johnsongreen
nm · 2004 · cited in 3 New Mexico opinions naming this issue, 2007–2009
2 sentences

2009See Johnson, 2004-NMSC-029, ¶ 11 , 136 N.M. 348 , 98 P.3d 998 (stating the central focus in determining whether constitutional error was harmless is “whether there is a reasonable possibility the erroneous evidence might have affected the jury’s verdict”). {77} In my independent examination of the record, I cannot conclude beyond a reasonable doubt that the error in admitting this evidence was harmless.

2009See Johnson, 2004-NMSC-029, ¶ 11 , 136 N.M. 348 , 98 P.3d 998 (stating the central focus in determining whether constitutional error was harmless is “whether there is a reasonable possibility the erroneous evidence might have affected the jury’s verdict”). {77} In my independent examination of the record, I cannot conclude beyond a reasonable doubt that the error in admitting this evidence was harmless.

13
Blakely v. Washingtongreen
scotus · 2004 · cited in 3 New Mexico opinions naming this issue, 2005–2007
2 sentences

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

13
State v. Stanleygreen
nm · 2001 · cited in 1 New Mexico opinions naming this issue, 2020–2020
2 sentences

2020See, e.g., State v. Stanley, 2001-NMSC-037, ¶ 44 , 131 N.M. 368 , 37 P.3d 85 (“In light of the reversal of the evidentiary issues, we do not review [the d]efendant’s ineffective assistance of counsel claim or his issue dealing with the refusal of the trial court to hold a hearing on his motion for a new trial.”).

2020See, e.g., State v. Stanley, 2001-NMSC-037, ¶ 44 , 131 N.M. 368 , 37 P.3d 85 (“In light of the reversal of the evidentiary issues, we do not review [the d]efendant’s ineffective assistance of counsel claim or his issue dealing with the refusal of the trial court to hold a hearing on his motion for a new trial.”).

11
State v. Garciagreen
nm · 2005 · cited in 1 New Mexico opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., State v. Reymundo Carlos 12 Garcia, 2005-NMSC-017, ¶ 20 , 138 N.M. 1 , 116 P.3d 72 ; State v. Graham, 2005- 13 NMSC-004, ¶ 9-10, 137 N.M. 197 , 109 P.3d 285 ; State v. Brown, 1984-NMSC-014 , 14 ¶ 7, 100 N.M. 726 , 676 P.2d 253 . 15 {23} It is settled law in New Mexico that instructions on circumstantial evidence are 16 not to be given.

2018See, e.g., State v. Reymundo Carlos 12 Garcia, 2005-NMSC-017, ¶ 20 , 138 N.M. 1 , 116 P.3d 72 ; State v. Graham, 2005- 13 NMSC-004, ¶ 9-10, 137 N.M. 197 , 109 P.3d 285 ; State v. Brown, 1984-NMSC-014 , 14 ¶ 7, 100 N.M. 726 , 676 P.2d 253 . 15 {23} It is settled law in New Mexico that instructions on circumstantial evidence are 16 not to be given.

11
Kersey v. Hatchgreen
nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., State v. 13 Ortega, 1991-NMSC-084 , ¶ 72, 112 N.M. 554 , 817 P.2d 1196 , abrogated on other 14 grounds as recognized by Kersey v. Hatch, 2010-NMSC-020, ¶ 17 , 148 N.M. 381 , 15 237 P.3d 683 ; State v. Haynes, 2000-NMCA-060 , ¶ 23, 129 N.M. 304 , 6 P.3d 16 1026 ; Gallegos, 1993-NMCA-046 , ¶ 11; see also UJI 14-5020 comm. cmt. (“This 17 instruction, together with the reasonable doubt instruction, UJI 14-5060, makes an 18 instruction on the dangers of eyewitness testimony unnecessary.”).

2018See, e.g., State v. 13 Ortega, 1991-NMSC-084 , ¶ 72, 112 N.M. 554 , 817 P.2d 1196 , abrogated on other 14 grounds as recognized by Kersey v. Hatch, 2010-NMSC-020, ¶ 17 , 148 N.M. 381 , 15 237 P.3d 683 ; State v. Haynes, 2000-NMCA-060 , ¶ 23, 129 N.M. 304 , 6 P.3d 16 1026 ; Gallegos, 1993-NMCA-046 , ¶ 11; see also UJI 14-5020 comm. cmt. (“This 17 instruction, together with the reasonable doubt instruction, UJI 14-5060, makes an 18 instruction on the dangers of eyewitness testimony unnecessary.”).

11
United States v. Gary Halbertgreen
ca9 · 1981 · cited in 1 New Mexico opinions naming this issue, 2018–2018
1 sentence

2018Use of a Codefendant's Guilty Plea {14} "A codefendant's guilty plea may not be used as substantive evidence of a defendant's guilt." United States v. Woods , 764 F.3d 1242 , 1246 (10th Cir. 2014) (internal quotation marks and citation omitted); see also United States v. Halbert , 640 F.2d 1000 , 1004 (9th Cir. 1981) (per curiam) ("As a principle of general acceptance, the guilty plea or conviction of a codefendant may not be offered by the government and received over objection as substantive evidence of the guilt of those on trial."); Clemmons v. State , 352 Md. 49 , 720 A.2d 1170 , 1173 (19

11
State v. Ortegagreen
nm · 1991 · cited in 1 New Mexico opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., State v. 13 Ortega, 1991-NMSC-084 , ¶ 72, 112 N.M. 554 , 817 P.2d 1196 , abrogated on other 14 grounds as recognized by Kersey v. Hatch, 2010-NMSC-020, ¶ 17 , 148 N.M. 381 , 15 237 P.3d 683 ; State v. Haynes, 2000-NMCA-060 , ¶ 23, 129 N.M. 304 , 6 P.3d 16 1026 ; Gallegos, 1993-NMCA-046 , ¶ 11; see also UJI 14-5020 comm. cmt. (“This 17 instruction, together with the reasonable doubt instruction, UJI 14-5060, makes an 18 instruction on the dangers of eyewitness testimony unnecessary.”).

2018See, e.g., State v. 13 Ortega, 1991-NMSC-084 , ¶ 72, 112 N.M. 554 , 817 P.2d 1196 , abrogated on other 14 grounds as recognized by Kersey v. Hatch, 2010-NMSC-020, ¶ 17 , 148 N.M. 381 , 15 237 P.3d 683 ; State v. Haynes, 2000-NMCA-060 , ¶ 23, 129 N.M. 304 , 6 P.3d 16 1026 ; Gallegos, 1993-NMCA-046 , ¶ 11; see also UJI 14-5020 comm. cmt. (“This 17 instruction, together with the reasonable doubt instruction, UJI 14-5060, makes an 18 instruction on the dangers of eyewitness testimony unnecessary.”).

11
Evans v. Stategreen
nev · 2001 · cited in 1 New Mexico opinions naming this issue, 2016–2016
11
United States v. Williamsgreen
ca11 · 2008 · cited in 1 New Mexico opinions naming this issue, 2016–2016
11
Victor v. Nebraskagreen
scotus · 1994 · cited in 1 New Mexico opinions naming this issue, 2016–2016
11
People v. Hung Hao Nguyengreen
calctapp · 1995 · cited in 1 New Mexico opinions naming this issue, 2016–2016
11
In re G.S.green
mont · 2002 · cited in 1 New Mexico opinions naming this issue, 2015–2015
11
In Re GSgreen
mont · 2002 · cited in 1 New Mexico opinions naming this issue, 2015–2015
11
In Re the Welfare of M.S.S.green
minnctapp · 1991 · cited in 1 New Mexico opinions naming this issue, 2015–2015
11
Bullcoming v. New Mexicogreen
scotus · 2011 · cited in 1 New Mexico opinions naming this issue, 2013–2013
11
State v. Montoyagreen
nm · 2008 · cited in 1 New Mexico opinions naming this issue, 2012–2012
11
In Re GAULTgreen
scotus · 1967 · cited in 1 New Mexico opinions naming this issue, 2010–2010
11
State v. Crosbygreen
nm · 1920 · cited in 1 New Mexico opinions naming this issue, 2009–2009
11
State v. Warrengreen
nm · 2008 · cited in 1 New Mexico opinions naming this issue, 2009–2009
11
REULE SUN CORP. v. Vallesgreen
nm · 2008 · cited in 1 New Mexico opinions naming this issue, 2009–2009
11
State v. Bullcominggreen
nmctapp · 2008 · cited in 1 New Mexico opinions naming this issue, 2009–2009
11
Brown v. United Statesgreen
scotus · 1973 · cited in 1 New Mexico opinions naming this issue, 2004–2004
11
State v. Andradegreen
nmctapp · 1997 · cited in 1 New Mexico opinions naming this issue, 2003–2003
11
Johnson v. United Statesgreen
scotus · 1997 · cited in 1 New Mexico opinions naming this issue, 1999–1999
11
Galloway v. Joseygreen
fla · 1987 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Carpenter v. Jamersongreen
ohio · 1982 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
State v. Sansomgreen
nmctapp · 1991 · cited in 1 New Mexico opinions naming this issue, 1996–1996
11
State v. Dobbsgreen
nmctapp · 1983 · cited in 1 New Mexico opinions naming this issue, 1991–1991
11
In Re John Ballay, A/K/A Figeret Hoxha, Patientgreen
cadc · 1973 · cited in 1 New Mexico opinions naming this issue, 1975–1975
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 (35)

CaseCitedYears
Chapman v. California red
scotus · 1967
2 sentences

2004For this type of constitutional trial error, there is no dispute that Chapman sets forth the appropriate test for harmless error: the State must "prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained." Chapman, 386 U.S. at 24 , 87 S.Ct. 824 .

2004For this type of constitutional trial error, there is no dispute that Chapman sets forth the appropriate test for harmless error: the State must "prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained." Chapman, 386 U.S. at 24 , 87 S.Ct. 824 .

61969–2004
State v. Rivera green
nm · 2012
2 sentences

2025“Structural error exists only in a very limited class of cases, . . . includ[ing] such pervasive defects as racial discrimination in the selection of a grand jury, complete denial of the right to counsel, a significant defect in the reasonable-doubt instruction, and denial of the right to a public trial.” State v. Rivera, 2012- NMSC-003, ¶ 20, 268 P.3d 40 (text only) (citations omitted).

2025“Structural errors include such pervasive defects as racial discrimination in the selection of a grand jury, complete denial of the right to counsel, a significant defect in the reasonable-doubt instruction, and denial of the right to a public trial.” State v. Rivera, 2012-NMSC-003, ¶ 20 , 268 P.3d 40 .

22025–2025
State v. Gutierrez green
nm · 2007
2 sentences

2018The State has the burden on appeal to "establish[ ] beyond a reasonable doubt that the jury verdict was not tainted by the constitutional error." Gutierrez , 2007-NMSC-033 , ¶ 18, 142 N.M. 1 , 162 P.3d 156 ; see also Tollardo , 2012-NMSC-008 , ¶ 36, 275 P.3d 110 ("[T]he reasonable possibility standard continues to *540 resemble the reasonable doubt standard[.]" (internal quotation marks and citation omitted) ).

2018The State has the burden on appeal to "establish[ ] beyond a reasonable doubt that the jury verdict was not tainted by the constitutional error." Gutierrez , 2007-NMSC-033 , ¶ 18, 142 N.M. 1 , 162 P.3d 156 ; see also Tollardo , 2012-NMSC-008 , ¶ 36, 275 P.3d 110 ("[T]he reasonable possibility standard continues to *540 resemble the reasonable doubt standard[.]" (internal quotation marks and citation omitted) ).

22018–2024
State v. Barr green
nm · 2009
2 sentences

2013In applying the harmless beyond a reasonable doubt standard of review “a 11 reviewing court should only conclude that an error is harmless when there is no 12 reasonable possibility [that] it affected the verdict.” State v. Barr, 2009-NMSC-024 , 13 ¶ 53, 146 N.M. 301 , 210 P.3d 198 , overruled on other grounds by Tollardo, 2012- 14 NMSC-008, ¶ 37; see Tollardo, 2012-NMSC-008, ¶ 34 . 15 {38} The present case presents a factual scenario that is very similar to that in 16 Bullcoming v. New Mexico, 131 S. Ct. 2705 .

2013In applying the harmless beyond a reasonable doubt standard of review “a 11 reviewing court should only conclude that an error is harmless when there is no 12 reasonable possibility [that] it affected the verdict.” State v. Barr, 2009-NMSC-024 , 13 ¶ 53, 146 N.M. 301 , 210 P.3d 198 , overruled on other grounds by Tollardo, 2012- 14 NMSC-008, ¶ 37; see Tollardo, 2012-NMSC-008, ¶ 34 . 15 {38} The present case presents a factual scenario that is very similar to that in 16 Bullcoming v. New Mexico, 131 S. Ct. 2705 .

22012–2013
In Re WINSHIP green
scotus · 1970
2 sentences

2010Kent set the minimum procedural requirements for waiver proceedings, 383 U.S. at 566-67 , 86 S.Ct. 1045 ; In re Gault extended to juveniles the right to notice of charges, to counsel, to confrontation and to cross-examination of witnesses, and to the privilege against self-incrimination, 387 U.S. at 33-34, 41, 55-56 , 87 S.Ct. 1428 ; In re Winship gave juveniles the protection of the reasonable doubt standard, 397 U.S. at 367 , 90 S.Ct. 1068 . {56} At the same time, the Court has repeatedly emphasized that it follows a more deferential approach to state decisions of how to administer their juv

2010Kent set the minimum procedural requirements for waiver proceedings, 383 U.S. at 566-67 , 86 S.Ct. 1045 ; In re Gault extended to juveniles the right to notice of charges, to counsel, to confrontation and to cross-examination of witnesses, and to the privilege against self-incrimination, 387 U.S. at 33-34, 41, 55-56 , 87 S.Ct. 1428 ; In re Winship gave juveniles the protection of the reasonable doubt standard, 397 U.S. at 367 , 90 S.Ct. 1068 . {56} At the same time, the Court has repeatedly emphasized that it follows a more deferential approach to state decisions of how to administer their juv

22004–2010
Jackson v. Virginia red
scotus · 1979
2 sentences

2007To support a conviction under a beyond a reasonable doubt standard, the evidence and inferences drawn from that evidence must be sufficiently compelling so that a hypothetical reasonable factfinder could have reached “a subjective state of near certitude of the guilt of the accused.” See Jackson, 443 U.S. at 315 , 99 S.Ct. 2781 .

2007To support a conviction under a beyond a reasonable doubt standard, the evidence and inferences drawn from that evidence must be sufficiently compelling so that a hypothetical reasonable factfinder could have reached “a subjective state of near certitude of the guilt of the accused.” See Jackson, 443 U.S. at 315 , 99 S.Ct. 2781 .

22001–2007
Williams v. New York green
scotus · 1949
2 sentences

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

22005–2005
Ritchie v. State green
ind · 2004
2 sentences

2005As the Supreme Court held in Booker, Apprendi’s requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. “[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

2005As the Supreme Court held in Booker, Apprendi's requirement of a jury finding beyond a reasonable doubt does not apply to a discretionary sentencing judgment between two statutory penalties that are available on the basis of an existing jury verdict, which in this case includes the verdict of guilt on the crime of first degree murder and the determination that an aggravating circumstance exists beyond a reasonable doubt. "[T]he federal constitution requires that eligibility for the death penalty be determined by the jury beyond a reasonable doubt, but it does not require that the decision whet

22005–2005
State v. Bell green
nmctapp · 1977
2 sentences

1991See State v. Trujillo, 95 N.M. 535 , 624 P.2d 44 (1981); State v. Dobbs, 100 N.M. 60, 67 , 665 P.2d 1151, 1158 (Ct.App. 1983) (citing Chapman v. California, 386 U.S. 18 , 87 S.Ct. *885 824, 17 L.Ed.2d 705 (1967)); State v. Bell, 90 N.M. 160 , 560 P.2d 951 (Ct.App. 1977).

1991See State v. Trujillo, 95 N.M. 535 , 624 P.2d 44 (1981); State v. Dobbs, 100 N.M. 60, 67 , 665 P.2d 1151, 1158 (Ct.App. 1983) (citing Chapman v. California, 386 U.S. 18 , 87 S.Ct. *885 824, 17 L.Ed.2d 705 (1967)); State v. Bell, 90 N.M. 160 , 560 P.2d 951 (Ct.App. 1977).

21983–1991
State v. Jones green
nmctapp · 1969
2 sentences

1972(State v. Jones, 80 N.M. 753 , 461 P.2d 235 (1969) ).

1972(State v. Jones, 80 N.M. 753 , 461 P.2d 235 (1969) ).

21971–1972
State v. Graham green
nm · 2005
2 sentences

2018See, e.g., State v. Reymundo Carlos 12 Garcia, 2005-NMSC-017, ¶ 20 , 138 N.M. 1 , 116 P.3d 72 ; State v. Graham, 2005- 13 NMSC-004, ¶ 9-10, 137 N.M. 197 , 109 P.3d 285 ; State v. Brown, 1984-NMSC-014 , 14 ¶ 7, 100 N.M. 726 , 676 P.2d 253 . 15 {23} It is settled law in New Mexico that instructions on circumstantial evidence are 16 not to be given.

2018See, e.g., State v. Reymundo Carlos 12 Garcia, 2005-NMSC-017, ¶ 20 , 138 N.M. 1 , 116 P.3d 72 ; State v. Graham, 2005- 13 NMSC-004, ¶ 9-10, 137 N.M. 197 , 109 P.3d 285 ; State v. Brown, 1984-NMSC-014 , 14 ¶ 7, 100 N.M. 726 , 676 P.2d 253 . 15 {23} It is settled law in New Mexico that instructions on circumstantial evidence are 16 not to be given.

12018–2018
Clemmons v. State green
md · 1998
2 sentences

2018Use of a Codefendant's Guilty Plea {14} "A codefendant's guilty plea may not be used as substantive evidence of a defendant's guilt." United States v. Woods , 764 F.3d 1242 , 1246 (10th Cir. 2014) (internal quotation marks and citation omitted); see also United States v. Halbert , 640 F.2d 1000 , 1004 (9th Cir. 1981) (per curiam) ("As a principle of general acceptance, the guilty plea or conviction of a codefendant may not be offered by the government and received over objection as substantive evidence of the guilt of those on trial."); Clemmons v. State , 352 Md. 49 , 720 A.2d 1170 , 1173 (19

2018Use of a Codefendant's Guilty Plea {14} "A codefendant's guilty plea may not be used as substantive evidence of a defendant's guilt." United States v. Woods , 764 F.3d 1242 , 1246 (10th Cir. 2014) (internal quotation marks and citation omitted); see also United States v. Halbert , 640 F.2d 1000 , 1004 (9th Cir. 1981) (per curiam) ("As a principle of general acceptance, the guilty plea or conviction of a codefendant may not be offered by the government and received over objection as substantive evidence of the guilt of those on trial."); Clemmons v. State , 352 Md. 49 , 720 A.2d 1170 , 1173 (19

12018–2018
State v. Haynes green
nmctapp · 2000
1 sentence

2018See, e.g., State v. 13 Ortega, 1991-NMSC-084 , ¶ 72, 112 N.M. 554 , 817 P.2d 1196 , abrogated on other 14 grounds as recognized by Kersey v. Hatch, 2010-NMSC-020, ¶ 17 , 148 N.M. 381 , 15 237 P.3d 683 ; State v. Haynes, 2000-NMCA-060 , ¶ 23, 129 N.M. 304 , 6 P.3d 16 1026 ; Gallegos, 1993-NMCA-046 , ¶ 11; see also UJI 14-5020 comm. cmt. (“This 17 instruction, together with the reasonable doubt instruction, UJI 14-5060, makes an 18 instruction on the dangers of eyewitness testimony unnecessary.”).

12018–2018
State v. Brown green
nm · 1984
12018–2018
United States v. Woods green
ca10 · 2014
12018–2018
State v. Padilla green
nm · 2002
12012–2012
Kent v. United States green
scotus · 1966
12010–2010
County Court of Ulster Cty. v. Allen green
scotus · 1979
12009–2009
State v. Spearman green
nmctapp · 1972
12008–2008
State v. Tave green
nmctapp · 1996
12007–2007
Neder v. United States green
scotus · 1999
12004–2004
Harrington v. California red
scotus · 1969
12004–2004
Schneble v. Florida green
scotus · 1972
12004–2004
Beck v. Alabama green
scotus · 1980
12003–2003
Santosky v. Kramer green
scotus · 1982
12001–2001
Mathews v. Eldridge green
scotus · 1976
12001–2001
Sullivan v. Louisiana green
scotus · 1993
11998–1998
State v. Doe green
nmctapp · 1986
11987–1987
Matter of Valdez green
nm · 1975
11979–1979
Barnes v. United States green
scotus · 1973
11976–1976
Lessard v. Schmidt green
wied · 1972
11975–1975
In Re Pickles'petition green
fladistctapp · 1965
11975–1975
State v. Moore green
nm · 1938
11974–1974
Finch v. State green
ind · 1967
11971–1971
McAffee v. United States green
cadc · 1939
11947–1947

Statutes the citing opinions construe

NM § N.M. Stat. § 30-16-2 (4) NM § N.M. Stat. § 30-2-1 (4) NM § N.M. Stat. § 30-28-1 (4) NM § N.M. Stat. § 30-9-11 (4) NM § N.M. Stat. § 31-18-15 (4) NM § N.M. Stat. § 30-22-5 (3) NM § N.M. Stat. § 30-28-2 (3) NM § N.M. Stat. § 30-4-1 (3) NM § N.M. Stat. § 32A-4-2 (3) NM § N.M. Stat. § 66-8-102 (3) USC § 25u.s.c.1901 (3) USC § 25u.s.c.1912 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 1862 (1883–2026) TX 1722 (1911–2026) FL 748 (1973–2026) IL 678 (1905–2026) PA 508 (1919–2026) KS 495 (1925–2026) WA 404 (1930–2026) TN 357 (1970–2026) AZ 282 (1965–2026) GA 252 (1914–2026) OH 201 (1968–2026) ID 185 (1975–2026) NY 184 (1956–2024) CO 177 (1949–2026) LA 176 (1976–2026) MD 171 (1966–2026) MA 158 (1972–2026) HI 156 (1950–2026) IN 154 (1891–2026) WI 151 (1977–2026) MS 145 (1924–2026) MN 137 (1953–2026) AL 137 (1916–2024) CT 129 (1955–2025) MO 107 (1889–2023) NJ 105 (1967–2026) SC 103 (1976–2026) DC 101 (1969–2026) MI 92 (1968–2026) NC 86 (1898–2023) IA 81 (1878–2024) KY 76 (1922–2026) NH 74 (1976–2025) UT 73 (1970–2026) OR 70 (1894–2026) NV 69 (1967–2026) AR 68 (1908–2025) VA 65 (1919–2026) NM 53 (1947–2025) WV 53 (1912–2023) DE 42 (1979–2026) SD 42 (1911–2022) OK 39 (1973–2025) RI 36 (1971–2026) ME 32 (1971–2024) MT 31 (1974–2024) VT 25 (1899–2026) ND 23 (1977–2021) WY 22 (1974–2025) AK 20 (1975–2025) NE 19 (1968–2022) VI 3 (1995–2015) GU 2 (2025–2025)

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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