New Mexico v. Tollardo
Annotate this CaseDefendant Steve Tollardo was convicted by a jury of being an accessory to first-degree murder, being an accessory to kidnapping, conspiracy to commit murder, and conspiracy to commit kidnapping. He was acquitted of being an accessory to aggravated arson and conspiracy to commit aggravated arson. The Supreme Court addressed only one of the issues Defendant raised on appeal: whether the district court erred in advising the jury that two other individuals were convicted of conspiracy to commit second-degree murder in connection with the same homicide underlying the charges against Defendant. The Court concluded that the district court did err in mentioning the coconspirators' convictions, and that the error was not harmless. Accordingly, the Court reversed Defendant's convictions and remanded the case to the district court for a new trial. In reaching this holding, the Court reexamined its harmless error analysis and clarified that a review of the particular circumstances in each case, rather than mechanical application of a multi-factor test, must guide the inquiry into whether a given trial error requires reversal.
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