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

• Clovis Police Officers went to execute an arrest warrant for criminal trespass against the Defendant, who was seen with a purse. Upon arrest, an officer searched the Defendant's purse, finding a small baggie of methamphetamine inside a flashlight. The Defendant was charged with possession of a controlled substance (paras 3-3).

Procedural History

• State v. Ortiz, A-1-CA-34703, mem. op. ¶ 1 (N.M. Ct. App. Sept. 10, 2018) (nonprecedential): The Court of Appeals reversed the Defendant's conviction for possession of a controlled substance, concluding the district court erred in denying the Defendant's motion to suppress evidence obtained from a warrantless search.

Parties' Submissions

• Plaintiff-Petitioner (State): Argued the search of the Defendant's purse and flashlights was a search incident to a lawful arrest, and even if not, the methamphetamine would have been inevitably discovered at the jail (para 4).
• Defendant-Respondent: Contended the warrantless search of her purse was unreasonable under the search-incident-to-arrest exception and that the methamphetamine would not have been inevitably discovered, rendering it inadmissible (para 5).

Legal Issues

• Whether the State met its burden to establish the reasonableness of the warrantless search of the Defendant's purse under the search-incident-to-arrest exception.
• Whether the methamphetamine would have been inevitably discovered, rendering the search reasonable under the inevitable discovery doctrine.

Disposition

• The Supreme Court of the State of New Mexico affirmed the Court of Appeals' reversal of the district court's denial of the Defendant's motion to suppress and remanded the case to the district court to vacate the Defendant's conviction and sentence (para 30).

Reasons

• VARGAS, Justice, with C. SHANNON BACON, Chief Justice, and DAVID K. THOMSON, Justice concurring:
  The Court held the State failed to meet its burden to demonstrate the reasonableness of the warrantless search of the Defendant's purse as it could not establish the purse was within the Defendant's immediate control at the time of the search, a requirement for the search-incident-to-arrest exception to apply (paras 6, 16).
  The Court found the district court erred in taking judicial notice of the jail’s inventory process without establishing on the record how this process was generally known or could be accurately and readily determined. Consequently, the Court concluded the State did not meet its burden to demonstrate that the methamphetamine would have been inevitably discovered (paras 22, 27).
  The Court emphasized the importance of making a sufficient record to support the reasoning justifying a warrantless search and when taking judicial notice under Rule 11-201 NMRA (paras 1, 27).