This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A minor was stopped for speeding at 80 mph in a 60 mph zone. Upon investigation, law enforcement discovered the minor was driving with a suspended or revoked license and was in possession of alcohol. The vehicle was impounded, and during an inventory search, officers found marijuana wrapped in a piece of newspaper inside an ashtray located behind the passenger seat (paras 2-3, 7-9).
Procedural History
- Children's Court of Rio Arriba County: Granted the minor's motion to suppress evidence of marijuana found during the inventory search, ruling that the officer exceeded the lawful bounds of the search by opening the newspaper based on a belief it contained drugs (paras 10-12).
Parties' Submissions
- Appellant (State): Argued that the inventory search was conducted lawfully under established procedures and that the subjective intent of the officer in opening the newspaper should not invalidate the search (paras 13, 21).
- Appellee (Child): Contended that the officer's act of opening the newspaper was not in accordance with established police procedures and was based solely on the officer's suspicion of drugs, rendering the search unlawful (para 22).
Legal Issues
- Was the inventory search of the vehicle conducted in accordance with established police procedures?
- Did the officer's subjective belief that the newspaper contained drugs invalidate the inventory search?
Disposition
- The Court of Appeals reversed the Children's Court's suppression order and remanded the case for further findings on whether the opening of the newspaper was consistent with established police procedures (para 23).
Reasons
Per Donnelly J. (Apodaca and Hartz JJ. concurring):
The Court held that the validity of an inventory search depends on whether it is conducted in accordance with established police procedures, not on the subjective intent of the officer conducting the search. The Children's Court erred by focusing on the officer's belief that the newspaper contained drugs rather than determining whether the search adhered to standardized procedures. The Court emphasized that inventory searches serve legitimate purposes, such as protecting property and shielding officers from liability, and may include the inspection of closed containers if done under established protocols. The case was remanded for additional findings on whether the officer's actions complied with such procedures (paras 13-23).