New Mexico v. Holt
Annotate this CaseAnthony Holt had partially removed a window screen from a residential dwelling when he the homeowner detected him. He fled. In the process of removing the screen, he placed his fingers behind the screen and inside the outer boundary of the home. Holt was subsequently arrested and charged with breaking and entering. An “unauthorized entry” was an essential element of the offense, and the issue this case presented for the New Mexico Supreme Court's review was whether Holt’s conduct constituted an “entry.” It did. Accordingly, the Court affirmed Holt’s conviction.
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