This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
In the early morning of May 7, 2006, Albuquerque police officers were dispatched to investigate an underage party involving alcohol at a hotel. As officers patrolled the parking lot, several vehicles began leaving, and seemingly underage individuals were seen running to cars. Officer Camacho stopped the Defendant's vehicle, detected signs of alcohol consumption, and arrested the Defendant for DWI after further investigation.
Procedural History
- District Court, Bernalillo County: Denied the Defendant's motion to suppress evidence, holding that there was reasonable and particularized suspicion to justify the stop.
Parties' Submissions
- Appellant (Defendant): Argued that the stop was unconstitutional as it lacked individualized suspicion, violating the Fourth Amendment.
- Appellee (State): Contended that the totality of the circumstances, including the dispatch purpose, patterns of flight at underage parties, and the Defendant's departure from the parking lot, provided reasonable suspicion to justify the stop.
Legal Issues
- Was there reasonable and particularized suspicion to justify the stop of the Defendant's vehicle under the Fourth Amendment?.
Disposition
- The Court of Appeals reversed the district court's denial of the motion to suppress, vacated the Defendant's conviction, and remanded the case for further proceedings.
Reasons
Per Bustamante J. (Fry CJ. concurring):
The Court found that the facts did not establish individualized suspicion sufficient to justify the stop under the Fourth Amendment. While the officers observed vehicles leaving the parking lot and individuals running to cars, these actions occurred in a public hotel setting where lawful activity is common. The State's reliance on proximity and association with other party-goers was insufficient to connect the Defendant to any specific illegal activity. The Court emphasized that suspicion based on mere association or generalized factors, as in prior cases like State v. Jones and State v. Eli L., does not meet the constitutional standard for reasonable suspicion.