This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A sheriff's deputy conducted a high-risk traffic stop on a Chevrolet Tahoe driven by the Defendant due to an invalid registration tag and an outstanding felony arrest warrant for the registered owner. The Defendant, who was not the registered owner, was arrested on an unrelated misdemeanor warrant. The vehicle was impounded, and during an inventory search, deputies found a closed Fritos canister in the Defendant's backpack, which contained fentanyl pills (paras 2-6).
Procedural History
- District Court, January 29, 2025: The court suppressed evidence of fentanyl pills found in the Fritos canister, ruling the search violated the New Mexico Constitution's protection against unreasonable searches (para 1).
Parties' Submissions
- Appellant (State): Argued that the search of the Fritos canister was within the lawful scope of the inventory search and that the Defendant had no reasonable expectation of privacy in the canister (paras 8, 12).
- Appellee (Defendant): Contended that the search of the Fritos canister was unreasonable and violated his constitutional rights, as he had a privacy interest in the canister (para 7).
Legal Issues
- Whether the Defendant had a reasonable expectation of privacy in the Fritos canister.
- Whether the search of the Fritos canister was within the lawful scope of a warrantless inventory search under the New Mexico Constitution.
Disposition
- The Court of Appeals affirmed the district court's decision to suppress the evidence found in the Fritos canister (para 28).
Reasons
Per Hanisee J. (Attrep C.J. and Bogardus J. concurring):
The Court found that the Defendant had a reasonable expectation of privacy in the Fritos canister due to its opaque nature and the presence of a lid, which indicated an intent to keep its contents private (paras 12-16). The Court rejected the State's argument that the canister's label negated this expectation (para 17). The search was deemed unreasonable as it did not further any of the three justifications for a warrantless inventory search: protecting the arrestee's property, protecting police from liability, or ensuring officer safety (paras 19-25). The Court emphasized that closed, locked, or sealed containers generally require a warrant for search unless justified by specific circumstances (para 26).