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 Clovis, New Mexico, near Webb’s Watering Hole, a State Police Officer stopped the Defendant's vehicle after observing a minor traffic violation. This stop led to the Defendant's arrest and charges for driving while intoxicated (DWI). The Defendant moved to suppress the evidence from the stop, arguing it was pretextual, aiming to investigate DWIs without reasonable suspicion, a claim supported by testimony from the officer and other drivers stopped under similar circumstances near the same location.
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Plaintiff-Appellant (State): Argued that the district court incorrectly applied the law by concluding the stop was pretextual; maintained that the officer's hunch, based on the Defendant's driving, was not pretextual; and requested the court to overrule the precedent set in State v. Ochoa to apply a standard of objective reasonableness to uphold the stop's validity.
- Defendant-Appellee: Contended that the stop was pretextual under State v. Ochoa, supported by testimony indicating a pattern of stops for minor traffic violations near the Bar to investigate DWIs without reasonable suspicion.
Legal Issues
- Whether the district court erred in finding the stop pretextual and in applying State v. Ochoa to DWI cases.
- Whether State v. Ochoa should be overruled to adopt a standard of objective reasonableness for evaluating traffic stops.
Disposition
- The Court of Appeals affirmed the district court's order granting the Defendant's motion to suppress evidence related to DWI charges.
Reasons
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Per J. MILES HANISEE, with concurrence from RODERICK T. KENNEDY and JAMES J. WECHSLER, the court found substantial evidence supporting the district court's determination that the stop was pretextual. Officer Telles admitted using minor traffic violations as a basis to investigate DWIs, a practice corroborated by testimony from other drivers. This pattern indicated a strategy of targeting drivers leaving the Bar for DWIs without reasonable suspicion or probable cause, violating the New Mexico Constitution. The court also rejected the State's argument to overrule Ochoa, citing Supreme Court precedent applying Ochoa to DWI contexts and affirming the totality of the circumstances test for evaluating the reasonableness of stops.
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