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

A confidential informant (CI) provided information to law enforcement about methamphetamine trafficking at a residence in Alamogordo, New Mexico. The CI claimed to have seen methamphetamine at the residence, handled by the Defendant, within the last 72 hours. The CI was deemed reliable based on past corroborated information and personal knowledge of methamphetamine. A search warrant was issued, leading to the discovery of methamphetamine and paraphernalia at the Defendant's residence and on her person (paras 3-4).

Procedural History

• District Court: Granted the Defendant's motion to suppress evidence, finding the affidavit for the search warrant lacked sufficient basis of knowledge (para 7).
• Court of Appeals: Reversed the District Court's decision, holding that the affidavit provided a sufficient basis for probable cause (para 8).

Parties' Submissions

• Defendant-Petitioner: Argued that the affidavit failed to demonstrate the CI's basis of knowledge and that the search warrant was overbroad (paras 5-6).
• State of New Mexico: Contended that the CI's first-hand observations provided a sufficient basis of knowledge and that the warrant was not overbroad (para 6).

Legal Issues

• Whether the information provided by a confidential informant in the affidavit for a search warrant satisfied the requirement of probable cause under the New Mexico Constitution (para 1).
• Whether the affidavit supporting the search warrant contained sufficient facts to enable the magistrate court to find probable cause (para 2).

Disposition

• The Supreme Court of New Mexico affirmed the Court of Appeals' decision, holding that the affidavit was sufficient to establish probable cause for the search warrant (para 21).

Reasons

Per Bacon J. (Thomson C.J., Zamora J., and Leos J. concurring):

The Court found that the affidavit provided a substantial basis for probable cause due to the CI's first-hand observations of methamphetamine at the Defendant's residence. The Court emphasized that first-hand observations can satisfy the basis-of-knowledge requirement under Rule 5-211(E) NMRA. The Court also noted that the affidavit contained sufficient detail to support the magistrate's determination of probable cause, aligning with the principles of the New Mexico Constitution and relevant case law (paras 22-34).

Vigil J., dissenting:

Justice Vigil dissented, arguing that the affidavit merely presented a conclusion without sufficient factual support to establish probable cause for trafficking. He emphasized that the affidavit lacked details about the quantity and packaging of methamphetamine, which are necessary to distinguish trafficking from mere possession. Vigil J. contended that the majority's decision undermines the constitutional requirement for a neutral magistrate to make an informed determination of probable cause (paras 45-60).