State of New Mexico, Plaintiff-Appellee v. Hector Flores Serna, Jr., Defendant-Appellant

Summary

The court held that prior convictions offered under the Im​​itation Controlled Substances Act must also satisfy the Rules of Evidence, and that the defendant’s prior drug-possession and fraud convictions were improperly admitted because they served only propensity purposes. The evidentiary error was harmless because the convictions received little emphasis and the remaining evidence of guilt was substantial. The court affirmed the convictions but remanded for correction of unauthorized habitual-offender and firearm enhancements to the defendant’s life sentence.