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

• The State of New Mexico appealed from the district court's orders suppressing evidence against Defendants Powell and Ramirez. The suppression was based on the lack of probable cause in obtaining a search warrant for the residence shared by the Defendants. The search warrant was sought based on the hearsay statements of a confidential informant (CC), who claimed to have firsthand knowledge of illegal narcotics at the Defendants' residence due to an ongoing relationship with them.

Procedural History

• Appeal from the District Court of Bernalillo County, Jacqueline D. Flores, District Judge, July 15, 2011: The district court issued orders suppressing the evidence against Defendants Powell and Ramirez for lack of probable cause in obtaining the search warrant.

Parties' Submissions

• State: Argued that the district court erred by finding the concerned citizen's visit and knowledge of illegal narcotics at the Defendants' residence insufficient for probable cause to approve the search warrant. The State also contended that the affidavit's details, despite lacking express basis for the CC's knowledge, were sufficient to satisfy probable cause.
• Defendants: [Not applicable or not found]

Legal Issues

• Whether the district court erred by finding that the concerned citizen's visit and knowledge of illegal narcotics at the Defendants' residence were insufficient to establish probable cause for the search warrant.
• Whether the affidavit, based on the hearsay statements of a confidential informant, met the two-pronged Aguilar/Spinelli test for probable cause.

Disposition

• The Court of Appeals affirmed the district court's orders suppressing the evidence against Defendants Powell and Ramirez.

Reasons

• Per Linda M. Vanzi, Judge (Celia Foy Castillo, Chief Judge, and Michael D. Bustamante, Judge, concurring): The Court of Appeals remained unpersuaded by the State's arguments, holding that the affidavit did not meet the Aguilar/Spinelli test for establishing probable cause. The affidavit failed to provide the basis for the confidential informant's knowledge or the timeframe when this knowledge was acquired. It also lacked details on whether the information was gathered reliably and contained no facts indicating the informant's credibility or the accuracy of the information. The Court rejected the State's request to infer the CC's recent and personal observation of a large-scale drug trafficking operation based on a vague statement about an ongoing relationship with Defendant Ramirez and an anonymous Crimestoppers call. The Court concluded that the affidavit lacked the necessary detail for a finding of probable cause, affirming the district court's ruling that the warrant was invalid and the resulting suppression of the evidence.