witness at the preliminary hearing (New Mexico) · Go Syfert
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witness at the preliminary hearing in New Mexico

6 New Mexico opinions name it 2 courts 1983–2024 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 (4)

CaseFollowedCited
State v. Lopezgreen
nm · 2011 · cited in 2 New Mexico opinions naming this issue, 2019–2024
2 sentences

2024Defendant’s argument instead is that she lacked a similar motive for cross-examining the witness at the preliminary hearing, due to the later disclosure by the State of lapel video from an investigating deputy. [BIC 17] This lapel video, disclosed the day after the victim’s preliminary hearing testimony, showed a woman on scene, “shortly after the robbery, in what could be described as a red coat,” and this woman was not Defendant. [BIC 1] In district court, Defendant argued that the State’s late disclosure of the video evidence limited Defendant’s “ability to meaningfully cross-examine” the v

2019See Lopez, 2011-NMSC-035, ¶ 12 (concluding that there was no Sixth Amendment Confrontation Clause violation when the defendant had an opportunity to and actually did cross-examine the witness at the preliminary hearing).

12
State v. Massengillgreen
nmctapp · 1983 · cited in 2 New Mexico opinions naming this issue, 1992–2011
2 sentences

2011Despite the change in the defendant’s theory, Gonzales concluded that because the defendant “was given the opportunity to cross-examine the witness at the preliminary hearing, [the] defendant was not denied the right to confront the witness against him.” Id. at 227, 824 P.2d at 1029 . {7} In Henderson, the preliminary hearing testimony of two unavailable witnesses was admitted at trial. 2006-NMCA-059, ¶ 7 , 139 N.M. 595 , 136 P.3d 1005 . “[T]he trial court acknowledged that [the defendant could not have cross-examined [the unavailable witnesses] at the preliminary hearing on all issues that we

1992Id.

12
State v. Gonzalesred
nm · 1992 · cited in 2 New Mexico opinions naming this issue, 2011–2011
2 sentences

2011We allowed the witness’s testimony to be 8 admitted, saying “the motive to cross-examine the witness at the preliminary hearing 9 was similar to the motive to cross-examine at trial because in both instances, the 10 issues were whether a crime was committed and whether the defendant had 11 committed the crime.” Id. at 226 , 824 P.2d at 1028 . 12 At the preliminary hearing in this case, Defendant had an opportunity and 13 similar motive to cross-examine Pollack.

2011We allowed the witness’s testimony to be 8 admitted, saying “the motive to cross-examine the witness at the preliminary hearing 9 was similar to the motive to cross-examine at trial because in both instances, the 10 issues were whether a crime was committed and whether the defendant had 11 committed the crime.” Id. at 226 , 824 P.2d at 1028 . 12 At the preliminary hearing in this case, Defendant had an opportunity and 13 similar motive to cross-examine Pollack.

12
State v. Hibbsgreen
nmctapp · 1971 · cited in 1 New Mexico opinions naming this issue, 1983–1983
2 sentences

1983See also State v. Hibbs, 82 N.M. 722 , 487 P.2d 150 (Ct.App.1971).

1983See also State v. Hibbs, 82 N.M. 722 , 487 P.2d 150 (Ct.App.1971).

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 (2)

CaseCitedYears
State v. Henderson green
nmctapp · 2006
2 sentences

2011Despite the change in the defendant’s theory, Gonzales concluded that because the defendant “was given the opportunity to cross-examine the witness at the preliminary hearing, [the] defendant was not denied the right to confront the witness against him.” Id. at 227, 824 P.2d at 1029 . {7} In Henderson, the preliminary hearing testimony of two unavailable witnesses was admitted at trial. 2006-NMCA-059, ¶ 7 , 139 N.M. 595 , 136 P.3d 1005 . “[T]he trial court acknowledged that [the defendant could not have cross-examined [the unavailable witnesses] at the preliminary hearing on all issues that we

2011Despite the change in the defendant’s theory, Gonzales concluded that because the defendant “was given the opportunity to cross-examine the witness at the preliminary hearing, [the] defendant was not denied the right to confront the witness against him.” Id. at 227, 824 P.2d at 1029 . {7} In Henderson, the preliminary hearing testimony of two unavailable witnesses was admitted at trial. 2006-NMCA-059, ¶ 7 , 139 N.M. 595 , 136 P.3d 1005 . “[T]he trial court acknowledged that [the defendant could not have cross-examined [the unavailable witnesses] at the preliminary hearing on all issues that we

12011–2011
State v. Holly green
nmctapp · 1968
2 sentences

1983In State v. Holly, 79 N.M. 516 , 445 P.2d 393 (Ct.App.1968), this Court decided on constitutional grounds that preliminary hearing testimony can be introduced at the trial where the witness is unavailable and the defendant had an opportunity to cross-examine and confront the witness at the preliminary hearing.

1983In State v. Holly, 79 N.M. 516 , 445 P.2d 393 (Ct.App.1968), this Court decided on constitutional grounds that preliminary hearing testimony can be introduced at the trial where the witness is unavailable and the defendant had an opportunity to cross-examine and confront the witness at the preliminary hearing.

11983–1983

Where else courts name it

PA 34 (1928–2026) CA 34 (1954–2025) IL 9 (1979–2026) AZ 8 (1972–1990) NM 6 (1983–2024) OK 4 (1967–1974) KS 4 (1978–2006) UT 4 (1903–2017) NV 4 (2014–2018) CO 4 (1986–2004) OH 3 (1979–2022) MO 3 (1960–2017) GA 2 (1966–1976) MD 2 (1969–1978) TN 2 (1977–2010) KY 2 (2003–2022)

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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