This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A state police officer observed the Defendant speeding in San Juan County, New Mexico, near the Navajo Reservation boundary. The Defendant, a Navajo Nation member, failed to stop when signaled and continued onto the reservation. After stopping, the officer noted signs of intoxication and administered field sobriety tests, which the Defendant voluntarily performed, revealing impairment. The officer, lacking jurisdiction to arrest on the reservation, allowed the Defendant to leave on foot. The Defendant was later charged with driving while intoxicated (DWI) based on evidence collected during the stop (paras 2-6).
Procedural History
- District Court of San Juan County: The Defendant was convicted of DWI, with the court determining it was his seventh offense, resulting in a third-degree felony sentence of three years imprisonment followed by two years of parole (headnotes, para 1).
Parties' Submissions
- Defendant-Appellant: Argued that the evidence from the field sobriety tests should be suppressed because the state officer lacked jurisdiction to detain and collect evidence on the Navajo Reservation without cross-commissioning by the Bureau of Indian Affairs (BIA) or the Navajo Nation (para 1, para 7).
- Plaintiff-Appellee: Contended that the officer had authority to stop the Defendant to investigate the traffic offense observed off the reservation and to determine jurisdiction. The Plaintiff also argued that the Defendant voluntarily consented to the field sobriety tests, making the evidence admissible (paras 7, 12-14).
Legal Issues
- Did the state officer have authority to stop the Defendant on the Navajo Reservation to investigate a traffic offense observed off the reservation and determine jurisdiction?
- Was the continued detention of the Defendant to administer field sobriety tests lawful under the Fourth Amendment?
- Did the Defendant voluntarily consent to the field sobriety tests, making the evidence admissible?
Disposition
- The Court of Appeals of New Mexico affirmed the district court’s judgment and sentence (para 16).
Reasons
Per Vigil J. (Pickard and Castillo JJ. concurring):
The Court held that the state officer had authority to stop the Defendant on the Navajo Reservation to investigate the traffic offense observed off the reservation and to determine jurisdiction. The Court relied on reasoning from similar cases, such as United States v. Patch and State v. Schmuck, which allowed brief stops to determine jurisdiction when the officer had reasonable suspicion of a traffic violation (paras 9-11).
The Court further found that the Defendant voluntarily consented to the field sobriety tests, as the officer testified that the Defendant agreed to perform them, and the Defendant did not challenge this testimony. The Court emphasized that consent is an exception to Fourth Amendment requirements, and there was no evidence of coercion (paras 12-14).
Finally, the Court noted that the officer respected Navajo Nation sovereignty by not arresting the Defendant and allowing him to leave on foot when no tribal officers were available. The Court concluded that there was no injury to the sovereignty of the Navajo Nation (para 15).