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

• On March 26, 2011, Deputy Terry McCoy observed the Defendant driving at thirty-five miles per hour in an area he believed had a speed limit of twenty-five miles per hour. This led to a traffic stop, during which evidence was collected resulting in charges against the Defendant for non-aggravated DWI, possession of an open container, and speeding. The area of the stop was later clarified to be a mixed-use zone without posted speed limit signs, though signs indicating a twenty-five miles per hour limit were installed subsequently (paras 4-5).

Procedural History

• Magistrate Court: Defendant was convicted of non-aggravated DWI, possession of an open container, and speeding.
• District Court of San Juan County: Granted Defendant's motion to suppress evidence obtained during the traffic stop, leading to the State's appeal (para 5).

Parties' Submissions

• State: Argued that despite the lack of posted speed limit signs and the mixed-use character of the area, Deputy McCoy had reasonable suspicion to stop the Defendant for speeding because the Defendant was driving at thirty-five miles per hour, which was above the presumed speed limit (paras 6-7).
• Defendant: Filed a motion to suppress the evidence obtained during the traffic stop, challenging the legality of the stop based on the actual speed limit applicable in the mixed-use area and the absence of posted speed limit signs (para 6).

Legal Issues

• Whether the district court correctly interpreted Section 66-7-301(A)(2) in concluding that it does not apply to mixed-use districts, thereby invalidating the traffic stop for lack of a numerical speed limit in such areas (para 8).
• Whether Deputy McCoy had reasonable suspicion to stop the Defendant even if he mistakenly believed the speed limit was twenty-five miles per hour instead of thirty miles per hour (para 8).

Disposition

• The Court of Appeals reversed the district court’s decision to grant the Defendant's motion to suppress and remanded the case for further proceedings (para 18).

Reasons

• The Court of Appeals, with Judge James J. Wechsler authoring the opinion and Judges Roderick T. Kennedy and M. Monica Zamora concurring, held that the district court's interpretation of the applicable speeding statute was inconsistent with legislative intent and led to an unreasonable result. The court found that the statute's speed limit of thirty miles per hour applies to areas containing either businesses or residences, regardless of whether the area contains both or is zoned for mixed use. The court also determined that Deputy McCoy had reasonable suspicion to stop the Defendant for speeding, despite his mistaken belief about the specific speed limit, because the Defendant was driving at a speed that violated the applicable statute. The court emphasized that a mistake of law by an officer does not invalidate a traffic stop if the facts observed support reasonable suspicion of a law violation (paras 9-17).