This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant executed a legal U-turn upon seeing a DWI checkpoint in the early hours of the morning. The officer, stationed before the checkpoint, stopped the Defendant's vehicle, suspecting an intent to evade the checkpoint. The Defendant was subsequently arrested for DWI (paras 2-3).
Procedural History
- Magistrate Court, May 18, 2006: Denied the Defendant's motion to suppress evidence, holding that the stop was valid under the checkpoint plan. The Defendant pled guilty to DWI but reserved the right to appeal the validity of the stop (para 4).
- District Court: Denied the Defendant's motion to suppress, finding the stop valid under the checkpoint plan and supported by independent reasonable suspicion (para 5).
Parties' Submissions
- Defendant-Appellant: Argued that the officer lacked reasonable suspicion to stop her vehicle and that the checkpoint plan could not justify the stop as it occurred outside the checkpoint's physical boundaries (paras 4, 7).
- Plaintiff-Appellee: Contended that the stop was valid under the checkpoint plan, which directed officers to stop vehicles appearing to avoid the checkpoint, and that the officer had independent reasonable suspicion based on the circumstances (paras 4, 7, 10).
Legal Issues
- Was the stop of the Defendant's vehicle valid under the checkpoint plan?
- Did the officer have independent reasonable suspicion to justify the stop?
Disposition
- The Court of Appeals reversed the denial of the Defendant's motion to suppress evidence (para 20).
Reasons
Per Castillo J. (Wechsler and Vigil JJ. concurring):
- The Court found that the stop occurred outside the physical boundaries of the checkpoint, and the checkpoint plan's directive to stop vehicles avoiding the checkpoint was invalid. The directive improperly allowed officers discretion to determine intent, which required independent reasonable suspicion (paras 7-13).
- The Court held that the officer lacked reasonable suspicion to stop the Defendant. The legal U-turn, even in conjunction with the time and location, did not constitute sufficient grounds for reasonable suspicion under New Mexico law (paras 15-19).
- The Court emphasized that reasonable suspicion must be based on specific, articulable facts indicating a law violation, which were absent in this case (paras 15-19).
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