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 felony and misdemeanor charges related to a civilian 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 criminal proceedings in the district court (paras 4-6, 9-11).
Procedural History
- District Court: The district court quashed the search warrants and suppressed the evidence, agreeing with the Defendant's arguments regarding jurisdiction and due process violations (paras 2, 12-13).
- State v. Chavez, 2023-NMCA-071: The Court of Appeals reversed the district court's decision, holding that the metro court had the authority to issue the warrants and that the omissions in the affidavits did not invalidate the warrants (para 2).
Parties' Submissions
- Defendant: Argued that the metro court lacked jurisdiction to issue search warrants post-indictment and that the affidavits were deceptive for not disclosing the pending district court proceedings (paras 6, 11).
- State: Contended that the metro court had concurrent jurisdiction to issue the warrants and that the omissions in the affidavits were immaterial to the determination of 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 the warrants?
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 while inferior courts have the authority to issue search warrants post-indictment, the district court retains the power to quash such warrants to ensure the orderly administration of justice. The district court did not abuse its discretion in quashing the warrants due to their conflict with the court's scheduling order and the misleading nature of the affidavits. The Court emphasized the importance of the prosecutor's duty of candor and noted that the State's conduct in seeking the second warrant while a motion to quash was pending constituted judge shopping. The Court also requested revisions to the relevant rules and forms to encourage full disclosure in similar situations (paras 3, 16-34).