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 case involves the suppression of evidence obtained through a search warrant. The affidavit supporting the warrant identified a residence where the officer interviewed the victim, who lived with her grandparents and the Defendant. However, the affidavit failed to establish a connection between the residence and the alleged crime, as it did not specify that the crime occurred at the identified location or that evidence could be found there.
Procedural History
- District Court, Bernalillo County: The district court granted the Defendant’s motion to suppress evidence, finding that the affidavit supporting the search warrant did not establish probable cause.
Parties' Submissions
- Appellant (State): Argued that the affidavit provided a substantial basis for the judge to find probable cause, asserting that only a probability of criminal conduct needed to be shown. The State contended that the affidavit sufficiently linked the residence to the alleged crime and the evidence sought.
- Appellee (Defendant): [Not applicable or not found]
Legal Issues
- Did the affidavit supporting the search warrant establish probable cause to search the identified residence?
Disposition
- The Court of Appeals affirmed the district court’s decision to suppress the evidence.
Reasons
Per Bustamante J. (Wechsler and Kennedy JJ. concurring):
The Court found that the affidavit failed to establish probable cause because it did not provide sufficient facts to connect the identified residence to the alleged crime. While the affidavit stated that the victim and her brother lived with their grandparents and the Defendant, it did not confirm that the residence where the victim was interviewed was the same location where the crime occurred or where evidence could be found. The affidavit merely asserted that evidence of a crime could be found at the residence without providing factual support for this assertion. The Court emphasized that probable cause must be established within the four corners of the affidavit, and reasonable inferences drawn from the affidavit did not remedy the deficiencies. As a result, the Court upheld the district court’s suppression of the evidence.