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

• The Defendant was stopped by Officer Mark Landavazo after a delay of five to fifteen seconds in proceeding through an intersection when a red light turned green. This delay was the sole basis for the stop, leading to the Defendant being ticketed for obstructing traffic under a City of Albuquerque Ordinance. There were no other cars at the intersection or on the adjoining streets at the time, and no other traffic violations were alleged (paras 2-3).

Procedural History

• Metropolitan Court: The court concluded that Officer Landavazo had reasonable suspicion to conduct his stop of Defendant and denied Defendant’s motion to suppress evidence obtained as a result of the stop. Defendant pled guilty, reserving his right to appeal the denial of his suppression motion (para 3).
• District Court of Bernalillo County: Affirmed the metropolitan court’s decision in a memorandum opinion (para 3).

Parties' Submissions

• Defendant-Appellant: Argued that Officer Landavazo did not have reasonable suspicion to stop the Defendant, as the delay in proceeding from a red light did not constitute obstructing traffic under the relevant city ordinance (para 3).
• Plaintiff-Appellee (State of New Mexico): Contended that the Defendant’s vehicle prohibited Officer Landavazo from proceeding forward through the intersection in the southbound lane, thus violating the ordinance regardless of the temporal or spatial extent of the obstruction (para 8).

Legal Issues

• Whether a five- to fifteen-second delay in proceeding from a red light turned green constitutes obstructing traffic in violation of the City of Albuquerque Ordinance (para 1).
• Whether the officer had reasonable suspicion for the stop based solely on the transitory delay (para 1).

Disposition

• The Court of Appeals of the State of New Mexico reversed the district court’s denial of Defendant’s motion to suppress, vacated Defendant’s conviction, and remanded for further proceedings consistent with the opinion (para 16).

Reasons

• Per Roderick T. Kennedy, Judge (Michael E. Vigil, Chief Judge, and Michael D. Bustamante, Judge, concurring):
  The court determined that a brief delay in proceeding through an intersection when a red light turns green does not legally constitute obstructing traffic under the City of Albuquerque Ordinance. It was held that the officer operated under an unreasonable mistake of law and lacked reasonable suspicion for the stop, leading to the conclusion that all evidence obtained as a result of the improper stop should have been suppressed (para 1).
  The court conducted a statutory analysis of the ordinance and concluded that the ordinance does not specify a time limit for proceeding after a green light nor does it require the entire public way to be obstructed to constitute a violation. The court found the State's interpretation of the ordinance to be overly broad and impractical, leading to an absurd result if every slight delay at a green light were considered an obstruction of traffic (paras 4, 10-15).
  The court emphasized the importance of interpreting ordinances in a manner that avoids absurd or unjust outcomes and aligns with common sense and the legislative intent of promoting public safety and efficiency. It was concluded that a delay of mere seconds after a mandatory stop does not obstruct the free use of the public way as intended by the ordinance (paras 11-15).