Governor's Organized Crime Prevention Commission v. Jaramillo

OPINION

EASLEY, Justice.

Jaramillo, the former New Mexico State Liquor Director, appeals from a contempt order entered by the district court after he failed to produce, at a hearing before the Governor’s Organized Crime Prevention Commission (Commission), certain documents pursuant to a subpoena duces tecum which the district court had previously ordered enforced. We reverse.

The case turns on whether Jaramillo waived his right against self-incrimination by failing to raise the issue at the subpoena enforcement hearing before the district court, rather than later at the agency hearing held…