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 stopped by a police officer for allegedly speeding in a 35 mph zone, with the officer pacing the Defendant's vehicle at 50 mph over a distance of less than half a mile. Upon being stopped, the officer observed signs of intoxication, including bloodshot and watery eyes, the smell of alcohol, and the Defendant's admission to consuming alcohol. Field sobriety tests were conducted, and the Defendant was subsequently arrested for driving while intoxicated (DWI).
Procedural History
- Metropolitan Court: The Defendant was convicted after a bench trial of speeding and DWI (first offense).
- District Court of Bernalillo County: The Defendant's on-record appeal was denied, and the convictions were affirmed.
Parties' Submissions
- Defendant-Appellant: Argued that the initial traffic stop lacked reasonable suspicion, the arrest lacked probable cause, and the trial court erred in denying a motion for a mistrial due to the premature admission of breath alcohol test (BAT) results.
- Plaintiff-Appellee: Contended that the officer had reasonable suspicion to stop the Defendant for speeding, probable cause to arrest for DWI based on observed signs of intoxication and field sobriety test results, and that the trial court properly allowed the State to cure the foundational issue with the BAT results.
Legal Issues
- Was the initial traffic stop justified by reasonable suspicion?
- Did the officer have probable cause to arrest the Defendant for DWI?
- Did the trial court err in denying the Defendant's motion for a mistrial due to the premature admission of BAT results?
Disposition
- The Court of Appeals affirmed the Defendant's convictions for speeding and DWI.
Reasons
Per Vigil J. (Wechsler and Sutin JJ. concurring):
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Reasonable Suspicion: The Court held that the officer had reasonable suspicion to stop the Defendant for speeding. The officer's testimony about pacing the Defendant's vehicle at 50 mph in a 35 mph zone was deemed credible. The trial court was entitled to reject the Defendant's version of events and weigh the evidence, including reasonable inferences.
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Probable Cause: The Court found that the officer had probable cause to arrest the Defendant for DWI. Observations of bloodshot and watery eyes, the smell of alcohol, the Defendant's admission to drinking, and his performance on field sobriety tests collectively supported the arrest. The totality of the evidence was sufficient to warrant a reasonable belief that the Defendant was driving while intoxicated.
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Mistrial: The Court concluded that the trial court did not abuse its discretion in denying the motion for a mistrial. Although the BAT results were mentioned prematurely, the trial court allowed the State to cure the foundational issue. The Court presumed that the trial judge, in a bench trial, could properly weigh the evidence and disregard any improperly admitted evidence. There was no indication that the trial court relied on the BAT results in its decision.