NM Supreme Court reverses ruling overturning 2016 murder conviction

Jeremiah Gurule waited nearly six years in jail before a jury convicted him in 2016 of murder and evidence tampering in the stabbing death of his girlfriend.

A divided New Mexico Supreme Court ruled last week that Gurule’s speedy trial rights were not violated because of lengthy considerations of his mental competence to stand trial.

The 3-2 decision by the state’s highest court reversed an earlier decision by the state Court of Appeals that overturned Gurule’s convictions on speedy trial violations.

Chief Justice Shannon Bacon wrote a dissenting opinion, arguing that the Court of Appeals was correct in overturning Gurule’s convictions.

“The majority upends this Court’s speedy trial jurisprudence in concluding that a delay of nearly six years in trying (Gurule) for murder is reasonable,” Bacon wrote in her dissent.

Gurule, 36, was convicted by a 2nd Judicial District Court jury of second-degree murder and tampering with evidence in the stabbing death of Elizabeth Brito, a University of New Mexico business student, on April 2, 2010.

Witnesses testified that Gurule had been smoking methamphetamine before he stabbed Brito 26 times in the neck while she was on the phone with a 911 operator. Both were 22 at the time.

Gurule has a projected release date of Nov. 25, 2025, “subject to change, based on his conduct,” New Mexico Correction Department spokeswoman Brittany Roembach said Friday.

The New Mexico Court of Appeals in 2019 reversed Gurule’s conviction in a split decision, remanding the case to District Court with instructions to dismiss the charges.

The appellate court ruled that the 70-month delay in the trial weighted heavily against state prosecutors and that Gurule’s constitutional rights to a speedy trial were violated.

The Supreme Court on Thursday reversed the Court of Appeals decision.

“The Court of Appeals erred in weighting that delay against the State,” Justice David Thomson wrote for the three-member majority.

“Instead, we weigh the reasons for the delay in large part against (Gurule) because much of the delay was the result of multiple considerations of (Gurule’s) competence to stand trial,” Thomson wrote.

The Supreme Court has previously ruled that delays resulting from competency do not affect the defendant’s speedy trial rights, he wrote.

Questions of mental competency “causes all other work on the case to stop” and “no criminal jeopardy confronts the defendant as long as a question of competence remains undecided,” Thomson wrote.

The delays were not a result of “bad faith or negligence” by prosecutors, the opinion said.

“We are concerned about an outcome that discourages the prosecution from requesting or agreeing to a competency evaluation for fear of having the case dismissed on speedy trial claims,” Thomson wrote.

In a dissenting opinion, Bacon wrote that delays stemming from competency evaluations should weigh against defendants only if the delays are “unreasonable.” In this case, the evaluations were reasonable, she wrote.

Although competency evaluations benefited Gurule, “they also are beneficial to the state in ensuring that it complies with its constitutional obligations,” Bacon wrote, with Justice Michael Vigil in concurrence.

Gurule “contends that he should not have to choose between his right to a speedy trial and his due process rights,” Bacon wrote. “We agree.”