This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Law enforcement officers stopped a vehicle based on a tip from a confidential informant, who claimed the occupants were delivering methamphetamine and had drugs in the vehicle. The informant provided specific details, including the vehicle's description and license plate number. During the stop, officers conducted a search and discovered methamphetamine. The defendants disputed the circumstances of the stop and search, alleging they were detained at gunpoint and did not consent to the search (paras 3-6).
Procedural History
- District Court, Santa Fe County: The court suppressed the evidence, ruling that the informant's tip did not establish reasonable suspicion for the vehicle stop. It rejected the defendants' arguments that the stop constituted an arrest requiring probable cause and that the search lacked valid consent (paras 1, 7-8).
Parties' Submissions
- Plaintiff-Appellant (State): Argued that the informant's tip, combined with the officer's testimony, provided reasonable suspicion to justify the vehicle stop. The State contended that the district court erred in suppressing the evidence (paras 1, 20-22).
- Defendants-Appellees (Gonzales and Quintana): Asserted that the informant's tip was uncorroborated and insufficient to establish reasonable suspicion. They also challenged the credibility of the officer's testimony and the informant's reliability (paras 7-8, 18).
Legal Issues
- Was the informant's tip sufficient to establish reasonable suspicion for the vehicle stop?
- Did the district court err in suppressing the evidence based on a lack of reasonable suspicion?
Disposition
- The Court of Appeals reversed the district court's order suppressing the evidence (para 30).
Reasons
Per Hartz CJ (Donnelly and Flores JJ. concurring):
The Court of Appeals found that the district court erred in concluding that the informant's tip did not establish reasonable suspicion. The court presumed the district court accepted the officer's uncontradicted testimony, as required by precedent, and noted that the informant had a proven track record of reliability, with a 90% case clearance rate (paras 2, 16-18).
The court emphasized that reasonable suspicion can be based solely on an informant's tip if the tip demonstrates both the informant's credibility and a sufficient basis of knowledge. Here, the informant personally observed methamphetamine in the vehicle earlier that day, providing a reliable basis for the tip. The informant's credibility was further supported by their history of providing accurate information to law enforcement (paras 20-25).
The court rejected the defendants' argument that corroboration of the tip was necessary, noting that corroboration is not required when the informant's credibility and basis of knowledge are adequately established. The court distinguished this case from others involving anonymous informants or insufficient evidence of credibility (paras 26-28).
The Court of Appeals concluded that the officers had reasonable suspicion to stop the vehicle based on the informant's tip and reversed the suppression order (paras 29-30).