This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
In May 2001, Albuquerque police conducted surveillance on a house suspected of drug activity due to heavy foot traffic. Officers observed the Defendant entering the house and leaving after a few minutes. When approached by officers, the Defendant fled, discarding an object later identified as crack cocaine. He was apprehended and arrested (paras 2-3).
Procedural History
- District Court of Bernalillo County: Denied the Defendant's motion to suppress the cocaine evidence, finding the officers had reasonable suspicion to stop him.
Parties' Submissions
- Defendant-Appellant: Argued that the police lacked reasonable suspicion for the investigatory stop and that the cocaine was discovered as a result of an unconstitutional seizure of his person (para 1).
- Plaintiff-Appellee: Contended that the Defendant was not seized under the Fourth Amendment until after he discarded the cocaine, making the evidence admissible (paras 1, 6-8).
Legal Issues
- Did the police have reasonable suspicion to conduct an investigatory stop of the Defendant?
- Was the cocaine evidence obtained as a result of an unconstitutional seizure under the Fourth Amendment?
Disposition
- The Court of Appeals affirmed the district court's denial of the Defendant's motion to suppress the cocaine evidence (para 10).
Reasons
Per Michael E. Vigil J. (Bustamante and Robinson JJ. concurring):
The Court held that under the Fourth Amendment, a person is seized only when physical force or submission to authority restrains their liberty. The Defendant neither submitted to the officers' authority nor was physically restrained until after discarding the cocaine. Therefore, the cocaine was not the fruit of an unlawful seizure (paras 6-8). The Court relied on the precedent set in California v. Hodari D., which established that evidence discarded before a seizure is not subject to suppression (paras 7-8). The Court affirmed the district court's decision, finding the denial of the motion to suppress correct for any reason, even though the lower court based its decision on reasonable suspicion (para 9).