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Decision Information

Citations - New Mexico Laws and Court Rules
Chapter 66 - Motor Vehicles - cited by 2,961 documents

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • On a July night, Officer Mervin Daniel observed Defendant Eric Bibeau's vehicle accelerating at a high rate of speed after turning onto 20th Street in Farmington, New Mexico. Based on this observation, Officer Daniel initiated a traffic stop for "exhibition of speed or acceleration," leading to Bibeau's arrest and charge for driving while intoxicated (DWI) (paras 2-3).

Procedural History

  • Magistrate court: Denied Defendant's motion to suppress evidence from the traffic stop and found Defendant guilty of DWI.
  • District court: Denied Defendant's motion to suppress evidence obtained from the traffic stop on appeal (para 3).

Parties' Submissions

  • Defendant-Appellant: Argued that the traffic stop was not supported by reasonable suspicion as it required an intent to display speed to others, which was not present due to the absence of other vehicles or persons and Officer Daniel’s patrol car not being in Defendant's line of sight. Also contended that the statute under which he was stopped was unconstitutionally vague (para 3).
  • Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

  • Whether the traffic stop was supported by reasonable suspicion under NMSA 1978, Section 66-8-115, given the circumstances of Defendant's acceleration.
  • Whether Section 66-8-115 is unconstitutionally vague in its requirement for an "exhibition of speed or acceleration" (paras 3, 7, 13, 22).

Disposition

  • The district court's denial of Defendant's motion to suppress evidence obtained from the traffic stop was affirmed (para 21).

Reasons

  • The Court, with Judge Jacqueline R. Medina writing and Judges Linda M. Vanzi and Briana H. Zamora concurring, held that Officer Daniel had reasonable suspicion to initiate the traffic stop based on Defendant's acceleration, even without evidence of Defendant's specific intent to display speed to others or loss of control of the vehicle. The Court found substantial evidence of potential onlookers at the time of Defendant's acceleration, satisfying the requirement for an "exhibition of speed or acceleration." The Court deferred the question of whether Section 66-8-115 requires a specific intent to display speed to others, as there was reasonable suspicion based on Defendant's actions. The Court also did not address Defendant's argument regarding the statute's vagueness, as it was not necessary for the decision (paras 1-22).
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