This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Police officers were dispatched to a residence following a report of a domestic dispute. One officer stopped the Defendant's vehicle, which was associated with the residence, without observing any reckless driving or signs of intoxication. During the stop, the officer noticed signs of alcohol consumption, conducted field sobriety tests, and arrested the Defendant for driving under the influence (paras 2-3).
Procedural History
- District Court of Doña Ana County: Denied the Defendant's motion to suppress evidence obtained during the stop (para 1).
Parties' Submissions
- Defendant-Appellant: Argued that the stop was illegal as it was not based on reasonable suspicion or exigent circumstances, and all evidence obtained as a result should be suppressed (para 1).
- Plaintiff-Appellee (State): Contended that the stop was lawful under a standard of "reasonableness" rather than reasonable suspicion or exigent circumstances (para 1).
Legal Issues
- Was the stop of the Defendant's vehicle lawful in the absence of reasonable suspicion or exigent circumstances?
- Can a stop be justified solely on the basis of a "reasonableness" standard?
Disposition
- The Court of Appeals reversed the district court's denial of the motion to suppress and remanded the case for further proceedings (para 11).
Reasons
Per Apodaca J. (Chavez and Black JJ. concurring):
The Court held that the stop of the Defendant's vehicle constituted a seizure under the Fourth Amendment, requiring justification by reasonable suspicion or exigent circumstances (paras 5-6). The State conceded that neither reasonable suspicion nor exigent circumstances were present and instead relied on a "reasonableness" standard, which the Court rejected (paras 6, 11).
The Court distinguished the facts of this case from State v. Hernandez, where specific and corroborated information justified a stop. Here, the officer acted on vague information and stopped the Defendant merely to check if "everything was okay," which did not meet the constitutional requirements for a lawful stop (paras 7-10). Consequently, the evidence obtained during the stop was deemed inadmissible, and the conviction was reversed (para 11).