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 Defendant was arrested at his home during a domestic disturbance and taken to the Dona Ana County Detention Facility. During the booking process, officers confiscated his wallet and an open pack of cigarettes. The Defendant repeatedly requested the return of the cigarettes, arousing suspicion. Upon searching the cigarette pack, officers discovered a packet of cocaine. The Defendant was subsequently charged with possession of cocaine (paras 2-3).
Procedural History
- District Court of Dona Ana County: Denied the Defendant's motion to suppress the cocaine found during the search.
Parties' Submissions
- Defendant-Appellant: Argued that the search of the cigarette pack violated his constitutional rights under the State and Federal Constitutions because it was not conducted pursuant to an established inventory procedure and was solely aimed at finding contraband (para 4).
- Plaintiff-Appellee: Contended that the search was a valid inventory search conducted in accordance with established procedures and furthered legitimate police interests, such as protecting the Defendant's property and safeguarding the detention facility (paras 7-8, 10).
Legal Issues
- Was the search of the Defendant's cigarette pack a valid inventory search under the State and Federal Constitutions?
- Did the search violate the Defendant's Fourth Amendment right to be free from unreasonable searches?
Disposition
- The Court of Appeals affirmed the trial court's denial of the Defendant's motion to suppress the cocaine (para 17).
Reasons
Per Alarid J. (Pickard and Flores JJ. concurring):
The Court held that the search of the Defendant's cigarette pack was a valid inventory search and did not violate the Fourth Amendment. The Court reasoned as follows:
Custody and Established Procedure: The cigarette pack was in police custody, and the search was conducted in accordance with established inventory procedures at the detention facility. Testimony from officers and training sergeants confirmed that the procedure required a thorough search of all items, including open cigarette packs (paras 6-9).
Reasonableness of the Search: The search was deemed reasonable as it furthered legitimate purposes of inventory searches, such as protecting the Defendant's property, safeguarding the police from false claims, and ensuring the safety of the detention facility. The Court emphasized that inventory searches do not require written procedures as long as they follow established practices (paras 10-13).
Suspicion of Contraband: The Court rejected the Defendant's argument that the search was investigatory rather than an inventory search. It noted that the lawfulness of an inventory search is independent of any suspicion of contraband, provided the search is conducted pursuant to established procedures (paras 11, 13).
Precedent: The Court relied on prior decisions, including State v. Boswell and South Dakota v. Opperman, to support the broad scope of lawful inventory searches and the legitimacy of searching all containers in an arrestee's possession (paras 10, 14-15).
The Court concluded that the search was lawful and affirmed the trial court's decision to deny the motion to suppress (para 17).