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

A confidential informant (CI) provided information to law enforcement that methamphetamine was seen at a residence in Alamogordo, New Mexico, handled by the Defendant. The CI claimed the Defendant kept a continuous supply of narcotics. Based on this information, a search warrant was issued, leading to the discovery of methamphetamine and paraphernalia at the Defendant's residence and on her person (paras 3-4).

Procedural History

• District Court: The court granted the Defendant's motion to suppress evidence, finding the affidavit for the search warrant did not satisfy the basis-of-knowledge requirement (para 7).
• Court of Appeals: Reversed the district court's decision, holding that the affidavit provided a sufficient basis for probable cause (para 8).

Parties' Submissions

• Defendant-Petitioner: Argued the affidavit failed to demonstrate the CI's basis of knowledge, citing a lack of detail about the methamphetamine's quantity and packaging. Also claimed the warrant was overbroad (paras 5-6).
• State of New Mexico: Contended the CI's first-hand observations provided a sufficient basis of knowledge and that the warrant was not overbroad (para 6).

Legal Issues

• Whether the affidavit for the search warrant satisfied the basis-of-knowledge requirement under Rule 5-211(E) NMRA.
• Whether the Court of Appeals erred in concluding there was a substantial basis to support a finding of probable cause for the search warrant.

Disposition

• The Supreme Court of New Mexico affirmed the Court of Appeals' decision, holding that the affidavit provided a sufficient basis for probable cause (para 21).

Reasons

Per Bacon J. (Thomson C.J., Zamora J., and Leos J. concurring):

The Court found that the CI's first-hand observations of methamphetamine at the Defendant's residence provided a substantial basis for the magistrate to find probable cause. The Court emphasized that first-hand observations can satisfy the basis-of-knowledge requirement under Rule 5-211(E) NMRA. The Court also noted that the affidavit contained sufficient detail to support the CI's personal knowledge and was not merely based on rumor or reputation. The Court rejected the district court's reliance on a nonprecedential case, Belknap, and clarified that the affidavit's specificity was adequate under the circumstances (paras 22-34).

Vigil J., dissenting:

Justice Vigil dissented, arguing that the affidavit merely presented a conclusion without factual support, failing to meet the constitutional requirement for probable cause. He contended that the affidavit lacked details about the methamphetamine's quantity and packaging, which are necessary to establish probable cause for trafficking. Justice Vigil emphasized that probable cause for possession does not equate to probable cause for trafficking and criticized the majority for allowing a warrant based on an unsupported conclusion (paras 45-60).