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 a police officer for speeding. During the stop, the officer approached the passenger side of the Defendant's vehicle and, after hearing the sound of the vehicle's electronic door unlocking, opened the passenger door without seeking explicit consent from the Defendant. The officer did not knock on the window or request permission to open the door (paras 3-4).
Procedural History
- District Court of McKinley County: The court denied the Defendant's motion to suppress evidence, concluding that the Defendant's act of unlocking the door constituted unequivocal consent for the officer to open the door (para 5).
Parties' Submissions
- Defendant-Appellant: Argued that the district court erred in finding that the Defendant gave unequivocal consent for the officer to search the vehicle. The Defendant contended that the officer's warrantless search was unreasonable as there was no consent given (para 2).
- Plaintiff-Appellee: Asserted that there was no "search" because the officer only intended to initiate contact with the Defendant by opening the door. The State argued that the sound of the door unlocking was an invitation for the officer to open the door (paras 9-10).
Legal Issues
- Whether the Defendant's act of unlocking the vehicle door constituted specific and unequivocal consent for the officer to open the door.
- Whether the officer's action of opening the vehicle door without a warrant constituted an unreasonable search under the Fourth Amendment and the New Mexico Constitution.
Disposition
- The Court of Appeals reversed the district court's denial of the Defendant's motion to suppress and remanded the case to the district court (para 15).
Reasons
Per Medina CJ. (Attrep and Wray JJ. concurring): The Court found that the act of unlocking the door was ambiguous and did not amount to specific and unequivocal consent. The testimony lacked the clarity necessary to establish consent, as the officer did not seek permission to open the door, nor did the Defendant provide an affirmative, direct oral statement or sign a consent form. The Court concluded that the officer's action of opening the door constituted a search requiring a warrant, and the State failed to prove that the search was reasonable under the Fourth Amendment (paras 12-14).