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 stopped by a police officer while walking through a vacant lot. During the encounter, the officer conducted a pat-down search, removed items from the Defendant’s pocket, and requested his identification to run a warrant check. The officer discovered an outstanding warrant, leading to the Defendant’s arrest. During booking, a baggy of cocaine was found in the Defendant’s sock, resulting in a charge of felony possession of a controlled substance.
Procedural History
- District Court, Doña Ana County: The Defendant’s motion to suppress evidence obtained during the encounter was denied.
Parties' Submissions
- Defendant-Appellant: Argued that the evidence of cocaine should be suppressed because the officer’s actions constituted an unlawful seizure under the Fourth Amendment, as there was no reasonable suspicion to justify the stop or detention.
- Plaintiff-Appellee: Contended that the Defendant consented to the stop, search, and provision of identification, and that the discovery of the contraband was sufficiently attenuated from any potential Fourth Amendment violation.
Legal Issues
- Was the Defendant unlawfully seized under the Fourth Amendment during the encounter with the police officer?
- Should the evidence of cocaine discovered during booking be suppressed as a result of the alleged unlawful seizure?
Disposition
- The Court of Appeals reversed the district court’s denial of the motion to suppress and remanded the case for further proceedings.
Reasons
Per Vigil J. (Sutin and Castillo JJ. concurring):
The Court held that the Defendant was unlawfully seized under the Fourth Amendment when the officer retained the Defendant’s property and requested his identification to run a warrant check. The totality of the circumstances, including the officer’s conduct and statements, would lead a reasonable person to believe they were not free to leave or decline the officer’s requests.
The Court relied on precedent from State v. Soto and City of Roswell v. Hudson, which established that similar police conduct constituted a seizure without reasonable suspicion. The officer in this case admitted he had no reasonable suspicion of criminal activity, and the Defendant’s compliance with the officer’s requests was not voluntary but coerced by the circumstances.
The Court rejected the State’s argument that the discovery of the contraband was attenuated from the Fourth Amendment violation, finding that the illegal detention directly led to the discovery of the outstanding warrant and subsequent evidence. The taint of the unlawful seizure was not dissipated.