State v. Cruz

Summary

The Supreme Court of New Mexico held that the state's Worthless Check Act applies to worthless payroll checks issued in exchange for labor, even when the checks are delivered after the pay period and therefore relate to an antecedent wage obligation. The court rejected a requirement that the exchange be contemporaneous and reversed the Court of Appeals' decision, remanding for consideration of the remaining appellate issues.

Holdings

1. The Act applies to worthless checks issued in exchange for labor even when the checks are delivered after the pay period and are not contemporaneous with the performance of the labor.
2. The antecedent or pre-existing debt exception no longer applies to criminal prosecutions under the modern Worthless Check Act.
3. The Act does not require a contemporaneous transaction or exchange; the phrase 'in exchange for anything of value' must be read broadly according to its terms and statutory context.

Questions Presented

1. Whether the New Mexico Worthless Check Act applies to checks issued in exchange for labor when the checks are delivered after the end of the pay period.
2. Whether the Act excludes checks issued to pay antecedent or pre-existing debts.
3. Whether the Act requires the exchange of a worthless check for something of value to be contemporaneous.

Disposition

reversed_and_remanded