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 conducted surveillance on the Defendant's residence based on information from a confidential informant alleging the Defendant would transport a large quantity of methamphetamine. Officers observed the Defendant engaging in various activities, including driving different vehicles and picking up passengers. The Defendant was later stopped for a window tint violation, which officers admitted was a pretext to investigate narcotics trafficking. During the stop, a canine search was conducted, leading to the discovery of methamphetamine in the Defendant's vehicle.
Procedural History
- District Court, Bernalillo County: The court granted the Defendant's motion to suppress evidence, finding the traffic stop was pretextual and violated the New Mexico Constitution's protections against unreasonable searches and seizures.
Parties' Submissions
- Appellant (State of New Mexico): Argued that the traffic stop was justified by reasonable suspicion of a window tint violation and that the officers also had reasonable suspicion of drug trafficking based on the confidential informant's information and the Defendant's observed behavior.
- Appellee (Defendant): Contended that the stop was pretextual, as the officers' primary intent was to investigate narcotics trafficking, not enforce traffic laws, and that the evidence obtained should be suppressed under New Mexico's heightened constitutional protections.
Legal Issues
- Was the traffic stop pretextual and therefore unconstitutional under the New Mexico Constitution?
- Did the officers have reasonable suspicion to justify the stop based on the confidential informant's information and the Defendant's behavior?
- Should the evidence obtained during the stop be suppressed?
Disposition
- The Court of Appeals affirmed the district court's decision to suppress the evidence.
Reasons
Per Kennedy J. (Bustamante and Robles JJ. concurring):
The Court held that the traffic stop was pretextual and violated the New Mexico Constitution's distinctively protective standards for searches and seizures. The officers candidly admitted that their primary intent was to investigate narcotics trafficking, not to enforce the traffic code. The Court relied on its prior decision in State v. Ochoa, which established that pretextual stops are incompatible with New Mexico's constitutional protections. The totality of the circumstances, including the officers' subjective intent and the lack of urgency in addressing the window tint violation, supported the district court's finding that the stop was unreasonable at its inception. Consequently, the evidence obtained during the stop was properly suppressed.