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 involved in a traffic stop while being in a vehicle with Donnie Hobbs, a suspect in an armed robbery investigation. During the stop, the Defendant attempted to retrieve her purse from the vehicle, leading to a confrontation with Deputy Martinez. The Deputy, citing concerns for officer safety given the context of the armed robbery investigation and the Defendant's behavior, conducted a warrantless search of the Defendant's purse, resulting in her arrest for possession of a controlled substance (methamphetamine).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant-Appellant: Argued that the district court erred in denying her motion to suppress evidence obtained from the warrantless search of her purse, contending the search was unlawful.
- Plaintiff-Appellee: Justified the warrantless search based on the circumstances of the armed robbery investigation, the Defendant's association with a suspect, and her aggressive behavior during the stop, which raised concerns for officer safety.
Legal Issues
- Whether the district court erred in denying the Defendant's motion to suppress evidence obtained from the warrantless search of her purse.
Disposition
- The appeal to affirm the order of probation based on the Defendant's conditional no-contest plea for possession of a controlled substance was granted.
Reasons
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Per LINDA M. VANZI, J. (JAMES J. WECHSLER, J., and CYNTHIA A. FRY, J., concurring): The court found the warrantless search of the Defendant's purse by Deputy Martinez to be justified under the circumstances. The involvement in an armed robbery investigation of the individual accompanying the Defendant, combined with the Defendant's aggressive behavior towards the officer when retrieving her purse, warranted a search for weapons to ensure officer safety. The court referenced State v. Vandenberg and State v. Gutierrez to support the legality of the search under these specific conditions, affirming the district court's decision to deny the motion to suppress the evidence obtained from the search.
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