AI Generated Opinion Summaries

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 was arrested after a domestic altercation with his girlfriend, during which officers observed physical signs of violence on her, including abrasions, red marks on her neck, and clumps of hair on the ground. During the arrest, a small packet of cocaine was found in the Defendant's pocket during a search later deemed unlawful by the trial court (paras 2-6).

Procedural History

• District Court of Dona Ana County: The trial court ruled the search of the Defendant's person was unlawful but denied the motion to suppress the cocaine evidence, applying the inevitable discovery doctrine (paras 1, 7).

Parties' Submissions

• Defendant-Appellant: Argued that the State failed to prove by a preponderance of the evidence that (1) he would have been arrested for domestic battery absent the discovery of cocaine, and (2) the cocaine would have been found during a lawful inventory search (para 8).
• Plaintiff-Appellee: Contended that the cocaine would have been inevitably discovered during a standard inventory search following the Defendant's lawful arrest for domestic battery (paras 1, 10).

Legal Issues

• Whether the inevitable discovery doctrine applies to admit evidence obtained during an unlawful search (para 8).
• Whether the State provided sufficient evidence to establish that the cocaine would have been discovered during a lawful inventory search following the Defendant's arrest for domestic battery (para 8).

Disposition

• The Court of Appeals affirmed the trial court's denial of the Defendant's motion to suppress the cocaine evidence (para 19).

Reasons

Per M. Christina Armijo J. (A. Joseph Alarid and Lynn Pickard JJ. concurring):

• The Court upheld the trial court's finding that the Defendant would have been arrested for domestic battery based on the evidence observed at the scene, including the victim's injuries and statements, which provided probable cause for the arrest. The officers' testimony was deemed credible, and the arrest was independent of the cocaine discovery (paras 11-14).
• The Court found that the State sufficiently demonstrated that the cocaine would have been discovered during a lawful inventory search conducted at the police substation. Testimony established that inventory searches were standard procedure to document personal items and prevent claims of lost or stolen property (paras 15-17).
• The Court rejected the Defendant's argument that the trial court improperly combined doctrines under hypothetical circumstances, holding that the inevitable discovery doctrine permits such a combination when supported by objective facts, as in this case (para 18).