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

• In November 2018, a Rio Rancho Police Department officer initiated a traffic stop on a driver for speeding. During the stop, the officer expanded the investigation to a DWI based on various observations, including the driver's avoidance of eye contact, failure to provide proof of insurance, and the officer's inability to detect the smell of alcohol due to the truck's lifted position. The driver was charged with driving under the influence and failure to maintain traffic lane but moved to suppress the evidence from the DWI investigation, arguing a lack of reasonable suspicion (paras 2-5).

Procedural History

• Rio Rancho Municipal Court: Defendant was convicted of both counts at a bench trial.
• Thirteenth Judicial District Court: On appeal, the court granted Defendant's motion to suppress evidence from the DWI investigation and dismissed the case, finding a lack of reasonable suspicion for the expanded traffic stop (para 5).

Parties' Submissions

• Plaintiff-Appellant (City of Rio Rancho): Argued that the officer had reasonable suspicion to expand the traffic stop into a DWI investigation based on observations such as speeding, failure to maintain lane, window orientation, avoidance of eye contact, red eyes, and the act of handing over registration instead of insurance proof (para 10).
• Defendant-Appellee (Cody M. Lattin): Contended that there was a lack of evidence of typical signs of alcohol impairment and supported the district court's finding of insufficient reasonable suspicion to justify the expansion of the traffic stop (para 10).

Legal Issues

• Whether the officer had reasonable suspicion to expand the initial traffic stop into a DWI investigation.

Disposition

• The district court's order to suppress evidence and dismiss the case was affirmed (para 17).

Reasons

• The Court of Appeals, with Judges Jacqueline R. Medina, Zachary A. Ives, and Shammara H. Henderson concurring, held that the district court's findings were supported by substantial evidence. The court emphasized that the officer's observations prior to the defendant leaving the vehicle were limited and did not justify an expanded investigation. The officer did not detect an odor of alcohol, could not conclusively determine if the defendant's speech was slurred or if his eyes were watery or bloodshot, and the mere act of handing over registration instead of insurance, speeding, and the orientation of the windows did not provide reasonable suspicion for a DWI investigation. The court applied a de novo review of the reasonable suspicion standard, considering the totality of the circumstances, and found that the officer lacked the necessary suspicion to justify the expansion of the traffic stop (paras 11-16).