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 at a sobriety roadblock where officers observed signs of impairment, including the smell of alcohol and marijuana, bloodshot and watery eyes, slurred speech, and failure to complete field sobriety tests correctly. The Defendant admitted to consuming alcohol and marijuana, and a subsequent test revealed a blood alcohol level of .10.
Procedural History
- District Court, Bernalillo County: The Defendant was convicted of Driving While Intoxicated (DWI) after the court found the sobriety roadblock constitutional and the evidence sufficient to support the conviction.
Parties' Submissions
- Defendant-Appellant: Argued that the sobriety roadblock was unconstitutional due to insufficient testimony regarding the length and nature of detentions, whether officers were in uniform, and what officers were instructed to say to drivers. Additionally, the Defendant claimed the evidence was insufficient to support the DWI conviction.
- Plaintiff-Appellee: Asserted that the roadblock met constitutional standards of reasonableness under the guidelines established in City of Las Cruces v. Betancourt and that the evidence presented was sufficient to support the conviction.
Legal Issues
- Was the sobriety roadblock constitutional under the reasonableness standard established in City of Las Cruces v. Betancourt?
- Was there sufficient evidence to support the Defendant’s conviction for Driving While Intoxicated?
Disposition
- The Court of Appeals affirmed the Defendant’s conviction for Driving While Intoxicated.
Reasons
Per Bustamante J. (Robles and Garcia JJ. concurring):
The Court held that the sobriety roadblock was constitutional under the reasonableness standard established in City of Las Cruces v. Betancourt. The lead officer’s testimony demonstrated compliance with the guidelines, including supervisory involvement, uniform procedures, advance publicity, and minimal intrusion on drivers. The roadblock was well-marked, caused no congestion, and limited detentions to no more than one and a half minutes. The Defendant’s arguments regarding the lack of specific testimony on certain details were unpersuasive, as the lead officer’s testimony sufficiently addressed the relevant factors.
The Court also found the evidence sufficient to support the DWI conviction. The Defendant exhibited multiple signs of impairment, admitted to consuming alcohol and marijuana, and had a blood alcohol level of .10. Viewing the evidence in the light most favorable to the verdict, the Court concluded that a reasonable fact-finder could determine the Defendant was impaired to the slightest degree.