New Mexico v. BegayAnnotate this Case
Trevor Begay pleaded no contest to a petty misdemeanor count of battery. The County Magistrate Court imposed a 182-day sentence, suspended 171 days, credited Begay with 11 days of pre-sentence confinement, and imposed supervised probation. Begay failed to comply with the terms of his probation; he neither completed a life skills class nor performed community service. The magistrate court consequently ordered Begay to appear for a hearing. When Begay failed to appear, the magistrate judge issued a bench warrant for his arrest. Had Begay complied with the terms of his probation, his original probationary sentence would have concluded on December 27, 2012. Instead, on that day, Begay was subject to an outstanding warrant. The question this case presented for the Supreme Court’s review was whether a magistrate court had jurisdiction to revoke probation when a defendant violated the terms of probation and was in bench-warrant status when the defendant’s original probationary period expired. The Court held that NMSA 1978, Section 31-20-8 (1977), does not deprive a magistrate court of jurisdiction to revoke a defendant’s probation under these circumstances. The Court reversed the contrary judgment of the Court of Appeals and remanded for the execution of the sentence imposed by the magistrate court.