Attorney General v. Montoya

OPINION

HARTZ, Chief Judge.

{1} Defendant appeals an order finding him criminally liable for contempt of court and sentencing him to serve 179 days in the Santa Fe County Jail. He contends that (1) the trial court erred in failing to provide him with counsel at the contempt hearing, (2) the trial court erred in quashing a subpoena directed to his former counsel, (3) there was insufficient evidence of guilt, and (4) the trial court applied an incorrect burden of proof in finding him in contempt. We reject his first three arguments. But because the trial court may have applied an incorrect burden…