This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- A New Mexico State Police Officer observed the Defendant's vehicle following another vehicle too closely and initiated a traffic stop. This stop led to the Defendant's conviction for driving while under the influence (DWI) and for following too closely. The Defendant challenged the constitutionality of the statute under which he was stopped and subsequently convicted, arguing it was unconstitutionally vague (paras 2-3).
Procedural History
- District Court of Luna County: Denied Defendant's motion to suppress evidence obtained after the stop, leading to his conviction for the traffic offenses (para 3).
Parties' Submissions
- Defendant-Appellant: Argued that the statute for following too closely is unconstitutionally vague, providing too much discretion to officers and insufficient guidance to the public on how closely they may follow another vehicle without violating the statute (para 4).
- Plaintiff-Appellee (State of New Mexico): [Not applicable or not found]
Legal Issues
- Whether the statute under which Defendant was stopped and convicted, for following another vehicle too closely, is unconstitutionally vague (para 4).
Disposition
- The Court of Appeals affirmed the district court's decision, denying the Defendant's motion to suppress and upholding his convictions (para 10).
Reasons
-
Per M. Monica Zamora, J. (J. Miles Hanisee and Stephen G. French, JJ., concurring): The Court found that the "reasonable and prudent" standard in the statute is not unconstitutionally vague. It provides adequate notice to drivers of what behavior is prohibited and does not invite ad hoc application or inconsistent enforcement. The Court relied on precedent from both within New Mexico and other jurisdictions, as well as a federal case, to support its conclusion. The Defendant's attempt to distinguish his case based on the state Constitution's supposed greater protection was not sufficiently developed for the Court to address. Thus, the statute was deemed to provide persons of ordinary intelligence a fair opportunity to understand what conduct is prohibited and to guide enforcement officials reasonably, thereby upholding its constitutionality (paras 4-9).
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