State Supreme Court upholds 2003 murder suspect’s extended commitment to NMBHI
On the evening of April 11, 2003, officers with the Las Vegas Police Department responded to a home on Sixth Street near Baca Avenue after receiving a call about a possible dead body. Those officers ultimately entered the home with a search warrant, and soon began investigating one of the city’s most gruesome homicides to date.
Ricky Quintana, who was 35 at the time, was arrested and charged with an open count of murder in the death of his roommate, Michael Grube.
Quintana answered the door with blood on his hands and pants, according to an affidavit for a search warrant filed in District Court in April of 2003.
Grube’s body was found covered in blood. He was nearly decapitated, and his body mutilated, including the removal of his genitals, which were disposed of in a trash can, according to the affidavit. While in police custody, Quintana began licking the blood off his hands.
The open count of murder was changed to a second-degree murder charge, and Quintana was also charged with tampering with evidence.
Quintana was found incompetent to stand trial and committed to the New Mexico Behavioral Health Institute. In 2006, the court found that Quintana remained incompetent to stand trial, that he remained a danger, and that clear and convincing evidence supported the prosecution’s charge of second-degree murder.
Finding that aggravating circumstances existed, the District Court ordered a three-year addition to Quintana’s statutory 15-year term of commitment to NMBHI.
Following treatment at NMBHI, in 2014, Quintana was found competent to stand trial, and criminal proceedings resumed. Quintana was acquitted of tampering with evidence, but the court found clear and convincing evidence existed to support the second-degree murder charge. Five more years were added to Quintana’s fifteen-year commitment to NMBHI, for a total commitment period of 20 years.
The court ruled that Quintana represented a threat to community safety because “if released without supervision, there (was) a danger that Defendant would be medically non-compliant and his psychosis would return,” according to the Supreme Court opinion written by Justice C. Shannon Bacon. The court also found that Quintana had been in a state of psychosis when he killed Grube, and during a separate incident where he attacked another person.
Quintana appealed the decision, arguing that enhancing a term of commitment based on aggravating circumstances is not permitted under the New Mexico Mental Illness and Competency Code. However, the Court of Appeals upheld the decision, concluding that Quintana was a danger because of the brutality of the killing and Quintana’s prior history of violent conduct.
Last week, in a unanimous ruling, the state’s Supreme Court affirmed the decision, concluding that under Section 31-9-1.5(D) of New Mexico statute, with clear and convincing evidence, a term of commitment “may include an enhancement due to aggravating circumstances which relate to a defendant’s dangerousness,” according to the opinion.
New Mexico law allows for criminal commitment to a mental health facility for defendants charged with certain felonies, up to the maximum sentence for the offense had the person been convicted.
Following criminal commitment, courts must review the defendant’s competency and dangerousness every two years to determine if their condition has changed.
Fourth Judicial District Attorney Tom Clayton told the Optic that in cases where criminal commitment has been used, the person can be released when that commitment period ends; however, if the facility they are being treated at feels more treatment is needed, the facility can petition the court to extend the commitment period.
Quintana is currently 53. His 20-year term of commitment is scheduled to end in April 2023.
