SANTA FE – The state Supreme Court today unanimously affirmed the first-degree felony murder conviction of Ameer Muhammad for fatally stabbing a man during a 2017 robbery in Albuquerque.
Muhammad was sentenced to life in prison for killing Aaron Sieben after an altercation outside a gasoline station. Muhammad took the victim’s wallet and fled after the stabbing.
In appealing his conviction, Muhammad argued that his statements to police should not have been admitted as evidence at trial because mental illness prevented him from understanding his constitutional rights and knowingly waiving them before speaking with police. He also argued that the jury should have been instructed to consider whether he acted in self-defense.
The Court concluded that Muhammad “knowingly and intelligently” waived his Miranda rights to remain silent and refuse to answer law enforcement questions without an attorney present.
During an initial police interview after his arrest, Muhammad asked for an attorney. A week later Muhammad waived his rights when officers went to the county jail to collect DNA samples and other evidence. He confessed to the killing without being asked a question by police and claimed he had been diagnosed with schizophrenia years earlier.
After being advised of his rights, Muhammad told police he approached the victim’s parked truck at the gasoline station, put a knife to Sieben’s chest and demanded money. Sieben rolled up his window but chased after Muhammad as the defendant walked away. Eyewitnesses saw Muhammad stab the victim.
The Court stated that each time police advised Muhammad of his rights he was able to “effectively and cogently articulate that he understood that he did not have to speak to the detectives and that they would use what he said as evidence against him. This is the level of understanding required for a waiver to be knowing and intelligent.”
A recording of Muhammad’s jailhouse interview with police, the Court wrote, “demonstrates that Defendant’s mental illness did not affect his understanding of his rights but rather his motivation for not exercising those rights.”
The Court determined there was not enough evidence to merit a jury instruction on self-defense.
“At most, there is evidence that Victim struck Defendant before Defendant stabbed Victim. There was no testimony that Victim had drawn a weapon before being stabbed,” the Court stated, noting that previous state Supreme Court rulings “have held that evidence of a simple battery against a Defendant is insufficient for a reasonable jury to find that the defendant acted reasonably by responding with deadly force.”
In addition to life imprisonment, Muhammad was sentenced to six months for shoplifting but he did not appeal that conviction.