non-constitutional error in New Mexico

50 New Mexico opinions name it 2 courts 2009–2024 9 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 (11)

Case	Followed	Cited
State v. Tollardogreen nm · 2012 · cited in 23 New Mexico opinions naming this issue, 2012–2023 2 sentences 2023Balancing the Lucero factors and harmless error 9 {23} Considering the Lucero factors together, we conclude that the probative value 10 of Defendant’s prior conviction for battery upon a peace officer did not outweigh its 11 prejudicial effect to Defendant and the district court abused its discretion by 12 admitting the prior conviction as impeachment evidence. 13 {24} Next, we consider whether the admission of the evidence is harmless error. 14 “A non-constitutional error is harmless when there is no reasonable probability the 15 error affected the verdict.” State v. Tollardo, 2012-NMSC-008, 2023Balancing the Lucero factors and harmless error 9 {23} Considering the Lucero factors together, we conclude that the probative value 10 of Defendant’s prior conviction for battery upon a peace officer did not outweigh its 11 prejudicial effect to Defendant and the district court abused its discretion by 12 admitting the prior conviction as impeachment evidence. 13 {24} Next, we consider whether the admission of the evidence is harmless error. 14 “A non-constitutional error is harmless when there is no reasonable probability the 15 error affected the verdict.” State v. Tollardo, 2012-NMSC-008,	15	23
State v. Torrezgreen nm · 2009 · cited in 4 New Mexico opinions naming this issue, 2010–2016 2 sentences 2016We further conclude that the error in 20 admitting this testimony was not harmless error. 6 1 {13} “To determine whether a non-constitutional error was harmless, we must assess 2 whether there is no reasonable probability that the error affected the verdict.” Torrez, 3 2009-NMSC-029, ¶ 33 . 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a	3	4
State v. Branchgreen nm · 2010 · cited in 4 New Mexico opinions naming this issue, 2011–2020 2 sentences 2020See State v. Branch, 2010-NMSC-042, ¶ 15 , 148 N.M. 601 , 241 P.3d 602 (“A non-constitutional error is harmless when there is no reasonable probability the error affected the verdict.” (alteration, internal quotation marks, and citation omitted)), overruled on other grounds by Tollardo, 2012-NMSC-008 , ¶ 37 n.6. 2020See State v. Branch, 2010-NMSC-042, ¶ 15 , 148 N.M. 601 , 241 P.3d 602 (“A non-constitutional error is harmless when there is no reasonable probability the error affected the verdict.” (alteration, internal quotation marks, and citation omitted)), overruled on other grounds by Tollardo, 2012-NMSC-008 , ¶ 37 n.6.	2	4
State v. Barrgreen nm · 2009 · cited in 13 New Mexico opinions naming this issue, 2009–2012 2 sentences 2012A reviewing court 4 should only conclude that a non-constitutional error is harmless when there is no 5 reasonable probability the error affected the verdict.” Barr, 2009-NMSC-024, ¶ 53 ; 6 see also Tollardo, 2012-NMSC-008, ¶ 43 (stating that consideration of whether an 7 error was harmless “requires an examination of the error itself, which depending upon 8 the facts of the particular case could include an examination of the source of the error 9 and the emphasis placed upon the error”). 10 In concluding that there was no reasonable probability that the error affected 11 the verdict and was t 2011Harmless error for 3 a non-constitutional violation occurs when “there is no reasonable probability the 4 error affected the verdict.” State v. Barr, 2009-NMSC-024, ¶ 53 , 146 N.M. 301 , 210 5 P.3d 198 (emphasis omitted).	1	13
State v. Sernagreen nm · 2013 · cited in 4 New Mexico opinions naming this issue, 2014–2022 2 sentences 2022“When assessing the probable effect of evidentiary error, [we] should evaluate all of the circumstances surrounding the error.” State v. Serna, 2013-NMSC-033, ¶ 23 , 305 P.3d 936 (internal quotation marks and citation omitted). 2021“Non-constitutional error is harmless when there is no reasonable probability the error affected the verdict.” State v. Serna, 2013-NMSC-033, ¶ 22 , 305 P.3d 936 (alteration, emphasis, internal quotation marks, and citation omitted).	1	4
State v. Guerragreen nm · 2012 · cited in 1 New Mexico opinions naming this issue, 2013–2013 2 sentences 2013See State v. 16 Guerra, 2012-NMSC-027, ¶ 19 , 284 P.3d 1076 (“Non-constitutional error is 17 reversible only if the reviewing court is able to say, in the context of the specific 18 evidence presented at trial, that it is reasonably probable that the jury’s verdict would 19 have been different but for the error.” (alteration, internal quotation marks, and 20 citation omitted)). 2013See State v. 16 Guerra, 2012-NMSC-027, ¶ 19 , 284 P.3d 1076 (“Non-constitutional error is 17 reversible only if the reviewing court is able to say, in the context of the specific 18 evidence presented at trial, that it is reasonably probable that the jury’s verdict would 19 have been different but for the error.” (alteration, internal quotation marks, and 20 citation omitted)).	1	1
State v. Aragongreen nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2012–2012 2 sentences 2012See, e.g., State v. Aragon, 2010-NMSC-008, ¶¶ 35, 37 , 147 7 1 N.M. 474 , 225 P.3d 1280 (applying constitutional harmless error analysis where the 2 erroneous admission of hearsay reports violated the defendant’s right of 3 confrontation), overruled on other grounds by Tollardo, 2012-NMSC-008 . 2012See, e.g., State v. Aragon, 2010-NMSC-008, ¶¶ 35, 37 , 147 7 1 N.M. 474 , 225 P.3d 1280 (applying constitutional harmless error analysis where the 2 erroneous admission of hearsay reports violated the defendant’s right of 3 confrontation), overruled on other grounds by Tollardo, 2012-NMSC-008 .	1	1
State v. Wilsongreen nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2012–2012 2 sentences 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a	1	1
State v. Gonzalesgreen nm · 2000 · cited in 1 New Mexico opinions naming this issue, 2012–2012 2 sentences 2012See, e.g., State v. Gonzales, 2000-NMSC-028 , ¶ 42, 129 N.M. 556 , 11 P.3d 131 (applying the "reasonable probability" standard to a non-constitutional error); Alvarez-Lopez, 2004-NMSC-030, ¶ 25 , 136 N.M. 309 , 98 P.3d 699 (applying the "reasonable possibility" standard to a constitutional error); State v. Zamarripa, 2009-NMSC-001, ¶ 52 , 145 N.M. 402 , 199 P.3d 846 (applying both the "reasonable possibility" standard and the requirement that the error be proven harmless beyond a "reasonable doubt"). 2012See, e.g., State v. Gonzales, 2000-NMSC-028 , ¶ 42, 129 N.M. 556 , 11 P.3d 131 (applying the "reasonable probability" standard to a non-constitutional error); Alvarez-Lopez, 2004-NMSC-030, ¶ 25 , 136 N.M. 309 , 98 P.3d 699 (applying the "reasonable possibility" standard to a constitutional error); State v. Zamarripa, 2009-NMSC-001, ¶ 52 , 145 N.M. 402 , 199 P.3d 846 (applying both the "reasonable possibility" standard and the requirement that the error be proven harmless beyond a "reasonable doubt").	1	1
State v. Rojogreen nm · 1998 · cited in 1 New Mexico opinions naming this issue, 2012–2012 1 sentence 2012This conclusion is not “clearly against the logic and effect of the facts and circumstances of the case.” Rojo, 1999-NMSC-001, ¶ 41 (internal quotation marks and citation omitted). {21} There is no reasonable probability that the jury’s verdict would have been different if the jury had access to the two exhibits during deliberation.	1	1
State v. Daygreen nmctapp · 1978 · cited in 1 New Mexico opinions naming this issue, 2009–2009 2 sentences 2009Cf. State v. Day, 91 N.M. 570, 573-74 , 577 P.2d 878, 881-82 (Ct.App.1978) (stating that the proper harmless error standard in a case of prosecutorial misconduct was whether there was a reasonable probability that the misconduct contributed to the conviction). {54} The reasonableness standards provide elasticity that is responsive to the appropriate level of certainty needed before a reviewing court can pronounce an error harmless. 2009Cf. State v. Day, 91 N.M. 570, 573-74 , 577 P.2d 878, 881-82 (Ct.App.1978) (stating that the proper harmless error standard in a case of prosecutorial misconduct was whether there was a reasonable probability that the misconduct contributed to the conviction). {54} The reasonableness standards provide elasticity that is responsive to the appropriate level of certainty needed before a reviewing court can pronounce an error harmless.	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (14)

Case	Cited	Years
State v. Leyba green nm · 2012 2 sentences 2022However, “[w]e now analyze whether this evidentiary error was merely harmless, in which case we could overlook it, or prejudicial, requiring reversal.” Leyba, 2012-NMSC-037, ¶ 23 . {31} Because admitting the DRC order form was an evidentiary error, we apply the non-constitutional error standard for harmless error. 2021In order to determine whether a district court’s erroneous application of the Rules of Evidence is harmless, “we apply the non- constitutional error standard for harmless error.” State v. Leyba, 2012-NMSC-037, ¶ 24 , 289 P.3d 1215 . {31} Under this standard, we assess the circumstances surrounding the error, which may include “an examination of the source of the error”; “evidence of [Child’s] guilt separate from the error”; “the importance of the erroneously admitted evidence in the prosecution’s case”; and “whether the error was cumulative or instead introduced new facts.” See Tollardo, 2012-	6	2017–2022
State v. Vargas green nmctapp · 2016 2 sentences 2017State v. Vargas, 2016-NMCA-038, ¶ 24 , 368 P.3d 1232 . 2017State v. Vargas, 2016-NMCA-038, ¶ 24 , 368 P.3d 1232 .	3	2017–2017
State v. Garcia green nmctapp · 2013 2 sentences 2014State v. Garcia, 2013-NMCA-064, ¶ 17 , 302 P.3d 111 , cert. denied, 2013-NMCERT-004 , 301 P.3d 858 . 9 {31} The evidence of Defendant’s guilt is overwhelming, and the minor error asserted by Defendant does not cause us to doubt the validity of the verdict. 2014State v. Garcia, 2013-NMCA-064, ¶ 17 , 302 P.3d 111 , cert. denied, 2013-NMCERT-004 , 301 P.3d 858 . {31} The evidence of Defendant’s guilt is overwhelming, and the minor error asserted by Defendant does not cause us to doubt the validity of the verdict.	3	2014–2014
State v. Armijo green nmctapp · 2013 2 sentences 2019“For purposes of harmless error review, violations of the rules of evidence are a non-constitutional error.” State v. Armijo, 2014-NMCA-013, ¶ 13 , 316 P.3d 902 . “[A] non-constitutional error is harmless when there is no reasonable probability the error affected the verdict.” Tollardo, 2012-NMSC-008, ¶ 36 (internal quotation marks and citation omitted). “[T]he reasonable probability standard requires a greater degree of likelihood that a particular error affected a verdict” than reasonable possibility standard for constitutional errors. 2019“For purposes of harmless error review, violations of the rules of evidence are a non-constitutional error.” State v. Armijo, 2014-NMCA-013, ¶ 13 , 316 P.3d 902 . “[A] non-constitutional error is harmless when there is no reasonable probability the error affected the verdict.” Tollardo, 2012-NMSC- 008, ¶ 36 (internal quotation marks and citation omitted). “[T]he reasonable probability standard requires a greater degree of likelihood that a particular error affected a verdict” than reasonable possibility standard for constitutional errors.	2	2019–2019
State v. Gutierrez green nm · 2007 2 sentences 2024“The [s]tate has the burden of establishing that the constitutional error was harmless beyond a reasonable doubt.” State v. Gutierrez, 2007-NMSC-033, ¶ 18 , 142 N.M. 1 , 162 P.3d 156 (internal quotation marks and citation omitted). “[A] constitutional error is harmless when there is no reasonable possibility it affected the verdict.” Tollardo, 2012-NMSC- 008, ¶ 36 (alteration, internal quotation marks, and citation omitted). 2024“The [s]tate has the burden of establishing that the constitutional error was harmless beyond a reasonable doubt.” State v. Gutierrez, 2007-NMSC-033, ¶ 18 , 142 N.M. 1 , 162 P.3d 156 (internal quotation marks and citation omitted). “[A] constitutional error is harmless when there is no reasonable possibility it affected the verdict.” Tollardo, 2012-NMSC- 008, ¶ 36 (alteration, internal quotation marks, and citation omitted).	1	2024–2024
Rex Rammell and Lynda Rammell v. State of Idaho neutral idaho · 2012 1 sentence 2014State v. Garcia, 2013-NMCA-064, ¶ 17 , 302 P.3d 9 111 , cert. denied, 2013-NMCERT-004 , 301 P.3d 858 . {31} The evidence of Defendant’s guilt is overwhelming, and the minor error asserted by Defendant does not cause us to doubt the validity of the verdict.	1	2014–2014
State v. Alvarez-Lopez green nm · 2004 2 sentences 2012See, e.g., State v. Gonzales, 2000-NMSC-028 , ¶ 42, 129 N.M. 556 , 11 P.3d 131 (applying the "reasonable probability" standard to a non-constitutional error); Alvarez-Lopez, 2004-NMSC-030, ¶ 25 , 136 N.M. 309 , 98 P.3d 699 (applying the "reasonable possibility" standard to a constitutional error); State v. Zamarripa, 2009-NMSC-001, ¶ 52 , 145 N.M. 402 , 199 P.3d 846 (applying both the "reasonable possibility" standard and the requirement that the error be proven harmless beyond a "reasonable doubt"). 2012See, e.g., State v. Gonzales, 2000-NMSC-028 , ¶ 42, 129 N.M. 556 , 11 P.3d 131 (applying the "reasonable probability" standard to a non-constitutional error); Alvarez-Lopez, 2004-NMSC-030, ¶ 25 , 136 N.M. 309 , 98 P.3d 699 (applying the "reasonable possibility" standard to a constitutional error); State v. Zamarripa, 2009-NMSC-001, ¶ 52 , 145 N.M. 402 , 199 P.3d 846 (applying both the "reasonable possibility" standard and the requirement that the error be proven harmless beyond a "reasonable doubt").	1	2012–2012
State v. Marquez green nm · 2009 2 sentences 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a	1	2012–2012
State v. Tom green nmctapp · 2010 2 sentences 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a	1	2012–2012
State v. Johnson green nm · 2010 2 sentences 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a 2012See 19 State v. Wilson, 2011-NMSC-001, ¶¶ 30, 39 , 149 N.M. 273 , 248 P.3d 315 (applying 20 non-constitutional harmless error analysis after assuming that the trial court 21 improperly admitted opinion testimony in violation of Rule 11-702 NMRA); State v. 6 1 Branch, 2010-NMSC-042, ¶¶ 14, 15 , 148 N.M. 601 , 241 P.3d 602 (employing the 2 non-constitutional standard for harmless error analysis because the error was an 3 evidentiary error involving a violation of Rule 11-404(B)); State v. Johnson, 2010- 4 NMSC-016, ¶ 43 n.3, 148 N.M. 50 , 229 P.3d 523 (noting that if the defendant had 5 raised a	1	2012–2012
State v. Zamarripa green nm · 2008 2 sentences 2012See, e.g., State v. Gonzales, 2000-NMSC-028 , ¶ 42, 129 N.M. 556 , 11 P.3d 131 (applying the "reasonable probability" standard to a non-constitutional error); Alvarez-Lopez, 2004-NMSC-030, ¶ 25 , 136 N.M. 309 , 98 P.3d 699 (applying the "reasonable possibility" standard to a constitutional error); State v. Zamarripa, 2009-NMSC-001, ¶ 52 , 145 N.M. 402 , 199 P.3d 846 (applying both the "reasonable possibility" standard and the requirement that the error be proven harmless beyond a "reasonable doubt"). 2012See, e.g., State v. Gonzales, 2000-NMSC-028 , ¶ 42, 129 N.M. 556 , 11 P.3d 131 (applying the "reasonable probability" standard to a non-constitutional error); Alvarez-Lopez, 2004-NMSC-030, ¶ 25 , 136 N.M. 309 , 98 P.3d 699 (applying the "reasonable possibility" standard to a constitutional error); State v. Zamarripa, 2009-NMSC-001, ¶ 52 , 145 N.M. 402 , 199 P.3d 846 (applying both the "reasonable possibility" standard and the requirement that the error be proven harmless beyond a "reasonable doubt").	1	2012–2012
State v. Alberico green nm · 1993 1 sentence 2010Alberico, 116 N.M. at 169 , 861 P.2d at 205 . 15 Improperly admitted evidence will not result in a reversal if the error was harmless. 16 See, e.g., State v. Torrez, 2009-NMSC-029, ¶ 33 , 146 N.M. 331 , 210 P.3d 228 17 (“To determine whether a non-constitutional error was harmless, we must assess 18 whether there is no reasonable probability that the error affected the verdict.”). 2 1 SANE Practitioner’s Testimony on Victim’s Injuries 2 A review of the transcript indicates that defense counsel (1) failed to object 3 to the SANE practitioner’s testimony regarding Victim’s injuries on 4 Daubert/	1	2010–2010
State v. Alberico green nm · 1993 1 sentence 2010Alberico, 116 N.M. at 169 , 861 P.2d at 205 . 15 Improperly admitted evidence will not result in a reversal if the error was harmless. 16 See, e.g., State v. Torrez, 2009-NMSC-029, ¶ 33 , 146 N.M. 331 , 210 P.3d 228 17 (“To determine whether a non-constitutional error was harmless, we must assess 18 whether there is no reasonable probability that the error affected the verdict.”). 2 1 SANE Practitioner’s Testimony on Victim’s Injuries 2 A review of the transcript indicates that defense counsel (1) failed to object 3 to the SANE practitioner’s testimony regarding Victim’s injuries on 4 Daubert/	1	2010–2010
Sullivan v. Louisiana green scotus · 1993 2 sentences 2009However, “ ‘[t]he inquiry ... is not whether, in a trial that occurred without the error, a guilty verdict would surely have been rendered, but whether the guilty verdict actually rendered in this trial was surely unattributable to the error.’ ” Id. ¶ 57 (quoting Sullivan v. Louisiana, 508 U.S. 275, 279 , 113 S.Ct. 2078 , 124 L.Ed.2d 182 (1993)). 2009However, “ ‘[t]he inquiry ... is not whether, in a trial that occurred without the error, a guilty verdict would surely have been rendered, but whether the guilty verdict actually rendered in this trial was surely unattributable to the error.’ ” Id. ¶ 57 (quoting Sullivan v. Louisiana, 508 U.S. 275, 279 , 113 S.Ct. 2078 , 124 L.Ed.2d 182 (1993)).	1	2009–2009

Statutes the citing opinions construe

NM § N.M. Stat. § 30-9-11 (6) NM § N.M. Stat. § 30-6A-3 (5) NM § N.M. Stat. § 30-22-5 (4) NM § N.M. Stat. § 66-7-201 (4) NM § N.M. Stat. § 66-8-101 (4) NM § N.M. Stat. § 30-2-1 (3) NM § N.M. Stat. § 30-6-1 (3) NM § N.M. Stat. § 30-6A-1 (3) NM § N.M. Stat. § 30-6A-2 (3) NM § N.M. Stat. § 33-2-34 (3) NM § N.M. Stat. § 66-8-102 (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

TX 277 (1998–2026) VA 158 (1991–2026) TN 54 (1996–2026) NM 50 (2009–2024) OH 30 (1984–2025) DC 23 (1991–2024) GA 11 (1984–2025) WA 11 (2002–2026) NJ 9 (2003–2025) KY 8 (1998–2025) AK 7 (1972–2025) PA 7 (1976–2018) NY 6 (1984–2018) IA 4 (2014–2020) NC 4 (1998–2024) KS 4 (2012–2022) CT 4 (1998–2021) FL 3 (1985–1999) CO 3 (2011–2012) AL 3 (2012–2013) DE 3 (1984–2001) WI 3 (1985–2005) IN 3 (2001–2025) GU 3 (2022–2025) MD 3 (1984–2022) OK 2 (2021–2026) NV 2 (2008–2019) UT 2 (2015–2019)

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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