DISCUSSION {18} In this appeal, Defendant asks us to clarify our holdings in State v. Knight , 2019-NMCA-060, 450 P.3d 462, cert. denied , 2019-NMCERT-009, 2019 WL 11720212 (No. S-1-SC-37832, Sep. 13, 2019), and State v. Franco , 2019-NMCA-057, 450 P.3d 439, cert. denied , 2019-NMCERT-008, 2019 WL 11717170 (No. S-1-SC-37817, Aug. 9, 2019). Specifically, Defendant asks us to hold that Knight and Franco do not allow for convictions based on "volitional conduct that inadvertently results in the possession, distribution, or manufacture of [SECM]."
Defendant’s argument relies on the analysis found in State v. Granillo , 2016-NMCA-094, 384 P.3d 1121. We recently rejected the same argument for a different subsection of this statute in State v. Franco , 2019-NMCA-057, ¶ 13, 450 P.3d 439, 2019 WL 2559725 (No. A-1-CA-35470, June 13, 2019). {13} In that case, as a matter of first impression, we addressed "the intent necessary to sustain a conviction for intentional distribution of child pornography under Section 30-6A-3(B)."
{¶8} "[G]eneral criminal intent" means '"purposely do[ing] an act which the law declares to be a crime.'" State v. Franco, 2019-NMCA-057, ¶ 16, 450 P.3d 439 (quoting UJI 14-141 NMRA). "[G]eneral criminal intent is satisfied if the [s]tate can demonstrate beyond a reasonable doubt that
{16} Substantial evidence is defined as "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." State v. Franco, 2019-NMCA-___, ___ P.3d ___ (No. A-1-CA-35470, June 13, 2019) (internal quotation marks and citation omitted). "[J]ury instructions become the law of the case against which the sufficiency of the evidence is to be measured."
Defendant argues, in the alternative, that the intent evidence was insufficient even if we conclude that the mens rea is general intent. {18} We recently rejected a nearly identical argument for a heightened mens rea under Section 30-6A-3(B) in State v. Franco, 2019-NMCA-___, ¶ 13, ___ P.3d ___ (No. A-1-CA-35470, June 13, 2019). Like Defendant, the Franco defendant also relied on Granillo in urging this Court to determine that general criminal intent was insufficient under Section 30-6A-3(B).