New Mexico v. Arrendondo
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Defendant Angel Arrendondo testified during his trial that he shot and killed Alfego "Ace" Aragon in self-defense. Defendant claimed that Aragon shot at him numerous times, wounding him once in the shoulder. Witnesses testified that Aragon did not own a gun and was not armed. The jury found Defendant guilty of first-degree murder, assault with intent to commit a violent felony, negligent child abuse, tampering with evidence, and shooting at a dwelling. Defendant raised several issues on appeal: (1) whether the trial court abused its discretion by denying Defendant a fifth continuance requested one week before trial to allow defense counsel an opportunity to examine an unidentified hard fragment found in the lining of the jacket Defendant wore on the day of the shooting; (2) whether there was sufficient evidence to prove Defendant's convictions for assault with intent to commit a violent felony against Nicole Rael, Aragon’s daughter, negligent child abuse, tampering with evidence, and shooting at a dwelling; (3) whether defense counsel ineffective because she failed to timely investigate the unidentified hard fragment in the jacket, and because she did not pursue a defense that Defendant was so intoxicated by heroin use that he could not form the specific intent to commit first-degree murder; (4) whether Defendant was denied his right to a speedy trial under the Sixth Amendment of the United States Constitution, a claim he raised for the first time on appeal. Upon review, the Supreme Court concluded that because the State failed to provide sufficient evidence to support Defendant's conviction for negligent child abuse and his conviction for tampering with evidence, the Court reversed those convictions. Furthermore, the Court reversed his conviction for assault with intent to commit a felony and remanded the case for a new trial on that issue. The Court affirmed Defendant's remaining convictions.
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