AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

Police officers found the Defendant asleep in his pickup truck in a parking lot, with signs of intoxication, including slurred speech, difficulty performing simple tasks, and a strong odor of alcohol. The keys to the vehicle were found in the Defendant's pocket, but the officers did not observe him driving. The Defendant admitted to being drunk and failed multiple field sobriety tests (paras 2-3).

Procedural History

• District Court: The criminal complaint for DWI was dismissed on the grounds that it failed to establish probable cause that the Defendant had operated a vehicle while intoxicated (para 1).
• Court of Appeals: Reversed the district court's decision, finding that the complaint established probable cause for DWI (para 1).

Parties' Submissions

• Defendant: Argued that the complaint and affidavit failed to establish probable cause for DWI, as there was no evidence he had operated the vehicle. The Defendant also contended that the district court properly dismissed the complaint under Rule 5-601(B) (paras 3, 6).
• State: Asserted that the district court lacked authority to dismiss the complaint pretrial, as the Rules of Criminal Procedure do not require a probable cause determination when the Defendant is released from custody. The State also argued that the facts presented a jury question as to whether the Defendant drove to the parking lot while intoxicated (paras 4-5, 8).

Legal Issues

• Did the district court have the authority to dismiss the complaint pretrial for lack of probable cause?
• Was the Defendant's motion to dismiss capable of determination without a trial on the merits under Rule 5-601(B)?

Disposition

• The Supreme Court of New Mexico affirmed the Court of Appeals' decision on different grounds and remanded the case to the district court for further proceedings (para 10).

Reasons

Per Serna J. (Maes CJ., Minzner, Bosson, and Chavez JJ. concurring):

• The district court lacked authority to dismiss the complaint pretrial because the Defendant's release from custody eliminated the need for a probable cause determination under the Rules of Criminal Procedure (para 4).
• The Defendant's motion to dismiss was not capable of resolution without a trial on the merits, as the State could reasonably assert the availability of additional evidence to establish the Defendant's operation of the vehicle (paras 7-8).
• The facts in the officer's affidavit, including the Defendant's intoxicated state and the absence of alcohol containers in the vehicle, could support a reasonable inference that the Defendant drove to the parking lot while intoxicated. This issue must be submitted to the fact-finder at trial (para 8).
• The Court declined to address the Court of Appeals' application of State v. Johnson, as the case was resolved on other grounds (para 9).