This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
On December 31, 1987, a fire occurred at the Defendant's residence, prompting the Albuquerque Fire Department to respond. During the investigation, an arson investigator observed equipment and chemicals associated with a methamphetamine lab, as well as handguns. Due to the potential hazard posed by the chemicals, a police impact team and chemist were called to the scene. The police seized the chemicals, lab equipment, handguns, and a briefcase found at the scene (paras 2-4).
Procedural History
- District Court of Bernalillo County: The Defendant was convicted of trafficking in a controlled substance by manufacturing and possession of drug paraphernalia. The trial court denied the Defendant's motion to suppress evidence, finding the warrantless search and seizures justified by exigent circumstances (headnotes, paras 1, 7).
Parties' Submissions
- Defendant-Appellant: Argued that the evidence, including the glassware, handguns, and briefcase, was obtained through an unlawful search and seizure in violation of the Fourth Amendment and the New Mexico Constitution. The Defendant contended that exigent circumstances did not exist after the fire was extinguished and the arson investigator had completed the cause and origin search (paras 1, 8-9).
- Plaintiff-Appellee: Asserted that the presence of hazardous chemicals created exigent circumstances justifying the warrantless entry and seizure of evidence. The Plaintiff also argued that the evidence was lawfully seized under the plain view doctrine (paras 7, 10, 16).
Legal Issues
- Whether the warrantless entry and seizure of evidence at the Defendant's residence were justified by exigent circumstances (para 1).
- Whether the seizure of the briefcase and its contents violated the Defendant's reasonable expectation of privacy (para 17).
Disposition
- The Court of Appeals of New Mexico affirmed the trial court's decision, upholding the denial of the Defendant's motion to suppress evidence and the convictions (para 19).
Reasons
Per Alarid J. (Bivins CJ. and Donnelly J. concurring):
The Court found that the presence of hazardous chemicals at the Defendant's residence constituted exigent circumstances justifying the warrantless entry and seizure of evidence. The arson investigator's initial entry was lawful, and the subsequent entry by Officer Griego was necessary to address the potential danger posed by the chemicals. The Court emphasized that exigent circumstances are determined by objective conditions, not the subjective intentions of the officers (paras 7, 10, 14-15).
The seizure of the glassware and handguns was valid under the plain view doctrine, as Officer Griego was lawfully on the premises due to the exigent circumstances (para 16). Regarding the briefcase, the Court acknowledged the Defendant's reasonable expectation of privacy but held that the hazardous conditions provided probable cause and exigent circumstances to justify its warrantless search. The contents of the briefcase were lawfully seized under the plain view doctrine (paras 17-18).
The Court concluded that the trial court's findings were supported by substantial evidence and affirmed the denial of the motion to suppress (para 19).