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 juvenile (the "Child") was observed by a police officer, along with other juveniles, near the scene of a reported possible breaking and entering. When the officer approached in a marked patrol car and ordered the group to stop, the juveniles fled. The officer pursued the Child, repeatedly identifying himself and commanding the Child to stop. The Child eventually complied after multiple commands. The Child later claimed he did not hear the officer and fled because he was skipping school.
Procedural History
- Special Master, District Court of Lea County: Found the Child committed the delinquent act of resisting, evading, or obstructing an officer and placed the Child on probation for up to two years.
Parties' Submissions
- Child-Appellant: Argued that the officer lacked reasonable suspicion to detain him and that the State failed to prove he knew the officer was attempting to apprehend him.
- State-Appellee: Contended that the officer had reasonable suspicion based on the circumstances and that the Child’s actions demonstrated knowledge of the officer’s intent to detain him.
Legal Issues
- Did the officer have reasonable suspicion to detain the Child?
- Did the State present sufficient evidence to prove the Child knew the officer was attempting to apprehend him?
Disposition
- The Court of Appeals affirmed the adjudication of delinquency.
Reasons
Per Linda M. Vanzi J. (Cynthia A. Fry CJ and Jonathan B. Sutin J. concurring):
Reasonable Suspicion: The Court held that the officer had reasonable suspicion to detain the Child. The officer was investigating a possible breaking and entering, observed juveniles matching the description near the scene, and noted their flight upon seeing the patrol car. The totality of the circumstances, including the time of day (a school day) and the juveniles’ flight, supported the officer’s authority to briefly detain the Child for questioning.
Knowledge of Apprehension: The Court found sufficient evidence that the Child knew the officer was attempting to apprehend him. The officer, in uniform and in close proximity, repeatedly identified himself and commanded the Child to stop. The Child’s flight and eventual compliance, along with his admission that he ran because he was skipping school, supported the inference that he understood the officer’s intent.
Distinguishing Precedent: The Court distinguished this case from prior decisions (e.g., State v. Jason L. and State v. Eli L.), emphasizing that the officer had particularized suspicion of the Child based on his presence near the crime scene and his flight. Unlike those cases, the Child’s actions provided additional grounds for reasonable suspicion.
Constitutional Considerations: The Court rejected the argument that the officer’s presence alone constituted a seizure under the New Mexico Constitution. The Child’s flight occurred before any seizure, and thus could be considered in evaluating reasonable suspicion.
The Court concluded that the State met its burden of proving the elements of resisting, evading, or obstructing an officer beyond a reasonable doubt and affirmed the adjudication.