Cases | State v. Clark, 990 P.2d 793 (N.M. 1999) | 2018
The defendant pled guilty to kidnapping in the first degree and capital murder, and was sentenced to death. The trial court allowed the victim’s parents to make brief statements to the jury. On appeal, the defendant claimed that introduction of the statements violated his rights to due process and a fair trial because evidence of the victim’s personal characteristics was irrelevant to prove the existence of aggravating circumstances of the crime and would inflame passions of the jury. The supreme court held that: (1) victim impact evidence, brief and narrowly presented, is admissible during the penalty phase of death penalty cases; (2) victim impact testimony is consistent with the Capital Felony Sentencing Act because it constitutes additional evidence as to the circumstances of the crime under N.M. Stat. Ann. §§ 31-20A-1(C) and 31-20A-2(B); and (3) admission of testimony did not violate the defendant’s right to due process and a fair trial. The statements were brief and not more inflammatory than the simple facts of the defendant’s crimes.