This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
During the execution of a no-knock search warrant at a residence in Clovis, New Mexico, police detained the Defendant, who was near the property but not named in the warrant. The Defendant was held on the ground for 15 minutes, during which a pat-down search revealed a knife and a glass pipe containing suspected methamphetamine residue. The Defendant was subsequently arrested and charged with possession of a controlled substance and drug paraphernalia (paras 2-4).
Procedural History
- District Court, Curry County: Denied the Defendant's motion to suppress evidence obtained during the search and detention.
Parties' Submissions
- Defendant-Appellant: Argued that the search warrant did not authorize his detention or search, as he was not named in the warrant and was not on the property described. He contended that the search and seizure violated his Fourth Amendment rights and that his mere presence near the property did not justify the officers' actions (paras 5-6).
- Plaintiff-Appellee: Asserted that the detention and search were reasonable under the circumstances, citing officer safety concerns and the Defendant's proximity to the property described in the warrant. The State also argued that the knife was in plain view, justifying the pat-down search (paras 9-10, 22).
Legal Issues
- Was the Defendant’s detention during the execution of the search warrant reasonable under the Fourth Amendment?
- Was the pat-down search of the Defendant lawful under the circumstances?
Disposition
- The Court of Appeals affirmed the district court's denial of the Defendant's motion to suppress (para 23).
Reasons
Per Vigil J. (Robles and Vanzi JJ. concurring):
Detention: The Court held that the Defendant’s detention was reasonable under the Fourth Amendment. Although the Defendant was not named in the warrant and was outside the property described, the officers acted reasonably in detaining him to determine his identity and connection to the premises. The no-knock warrant, which cited officer safety concerns, justified the temporary detention of individuals near the property during the search. The 15-minute detention was deemed reasonable given the circumstances and the need to secure the premises (paras 11-20).
Pat-Down Search: The Court found the pat-down search lawful, as the knife in the Defendant’s pocket was plainly visible, creating a reasonable suspicion that he was armed and potentially dangerous. The subsequent discovery of the glass pipe and methamphetamine was incidental to the lawful search (paras 21-22).
Preservation of Issues: The Court determined that the Defendant had adequately preserved his Fourth Amendment claims for appeal but failed to properly assert an independent claim under the New Mexico Constitution (paras 9-10).
The Court concluded that the officers acted within the bounds of the Fourth Amendment, and the evidence obtained during the search was admissible.