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

• On March 20, 2013, Chaves County Metro Narcotics Task Force executed a search warrant at a mobile home in Chaves County, New Mexico. During the operation, they received information about drug activity at an adjacent mobile home. While securing the second mobile home for a search warrant, officers encountered the Defendant, Caesar Ortiz-Castillo, as a passenger in a vehicle. Upon observing Defendant's suspicious movements, Sergeant Gonzales conducted a pat-down search, discovering a methamphetamine pipe and subsequently arresting Defendant. Further search revealed more contraband, leading to charges of trafficking controlled substances and possession of drug paraphernalia (paras 3-8).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred in denying his motion to suppress evidence, claiming the search and seizure were illegal. Also contended that the presentation of improper character evidence warranted a mistrial (paras 1, 10, 22).
• Plaintiff-Appellee: Maintained that the search and seizure were lawful under state and federal law and that any prejudice from the presentation of character evidence was mitigated by curative instructions (para 2).

Legal Issues

• Whether the district court erred in denying the Defendant's motion to suppress evidence on the grounds of illegal search and seizure.
• Whether the presentation of improper character evidence to the jury required a mistrial.

Disposition

• The Court of Appeals affirmed the district court’s denials of Defendant’s motion to suppress and motion for a mistrial. Defendant’s convictions were upheld (para 27).

Reasons

• The Court, per Judge James J. Wechsler, with Judges Roderick T. Kennedy and Timothy L. Garcia concurring, found that:
  The encounter between Defendant and law enforcement prior to his removal from the vehicle was consensual and did not constitute a seizure under the Fourth Amendment. The sudden movement by Defendant towards his waist justified the pat-down search for weapons, which led to the discovery of drug paraphernalia and subsequent lawful arrest (paras 11-17).
  The search of Defendant's person following his arrest, which revealed further contraband, was permissible as a search incident to arrest. The Court distinguished this case from State v. Barragan, noting that the officer in the present case had identified the item felt during the pat-down as contraband before its seizure (paras 18-20).
  Regarding the motion for a mistrial based on the introduction of evidence of uncharged criminal conduct (possession of marijuana), the Court concluded that the prosecutor's line of questioning was not an intentional elicitation of inadmissible testimony. The prompt instruction to the jury to disregard the statement about marijuana minimized any potential prejudice. Thus, the district court did not abuse its discretion in denying the motion for a mistrial (paras 21-26).