New Mexico Supreme Court

City of Farmington v. Pinon-Garcia

September 19, 20132013 NMSC 46

Summary

The New Mexico Supreme Court held that a district court reviewing a municipal court’s pre‑trial dismissal must conduct an independent, de novo determination of any pre‑trial motions raised, rather than merely holding a new trial. It rejected the appellant’s reliance on State v. Candelaria because the municipal proceeding was not on the record, and it affirmed the Court of Appeals while reversing the district court and remanding for proper de novo review.