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 indicted in the district court on several charges related to a car chase involving gunfire. After the indictment, a metro court issued two search warrants for the Defendant's oral swab and fingerprints. The Defendant argued that the metro court lacked jurisdiction to issue these warrants post-indictment and that the affidavits supporting the warrants were deceptive for not disclosing the pending district court proceedings (paras 2-3, 4-6, 9).
Procedural History
- District Court: Quashed the search warrants and suppressed the evidence, ruling that the metro court lacked jurisdiction post-indictment and that the State's actions violated due process (paras 2, 12-13).
- State v. Chavez, 2023-NMCA-071: The Court of Appeals reversed the district court, holding that the metro court had authority to issue the warrants and that the omissions in the affidavits did not invalidate them (para 2).
Parties' Submissions
- Defendant-Petitioner: Argued that the metro court lacked jurisdiction to issue search warrants post-indictment and that the affidavits were deceptive for not disclosing the district court proceedings (paras 2, 6, 11).
- Plaintiff-Respondent: Contended that the metro court had authority to issue the warrants and that the omissions in the affidavits were immaterial to probable cause. They also argued that the process of obtaining a search warrant does not involve counsel except for reviewing probable cause (paras 7, 11).
Legal Issues
- May a magistrate or metropolitan court issue a search warrant after a criminal prosecution has formally commenced in the district court?
- Did the omissions in the affidavits supporting the search warrants invalidate them?
- Did the district court have the authority to quash the warrants issued by the metro court?
Disposition
- The Supreme Court of New Mexico reversed the Court of Appeals, affirmed the district court's decision to quash the warrants, and remanded the matter to the district court (para 3).
Reasons
Per Vigil J. (Thomson C.J., Bacon, Vargas, and Zamora JJ. concurring):
The Court held that the metro court had the authority to issue search warrants post-indictment, as the rules of criminal procedure grant concurrent authority to issue warrants. However, the district court has inherent power to quash such warrants to ensure orderly and efficient administration of justice. The district court did not abuse its discretion in quashing the warrants due to their conflict with the scheduling order, the misleading nature of the affidavits, and the State's conduct in seeking the second warrant while a motion to quash the first was pending. The Court also requested revisions to the relevant rules and forms to encourage full disclosure in similar situations (paras 3, 16-24, 25-33, 34).