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Decision Information

Citations - New Mexico Laws and Court Rules
Constitution of New Mexico - cited by 6,045 documents

Decision Content

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Facts

  • On December 21, 2016, at approximately 10:00 p.m., Officer Daniel Sedillos observed the Defendant driving near the center line on a two-lane road. After making a U-turn to follow the Defendant, Officer Sedillos witnessed the Defendant swerve over the double yellow center line with both left tires before correcting back into his lane, leading to a traffic stop. The Defendant was cited for failure to maintain his lane and was ultimately arrested and charged with driving while intoxicated (DWI) (paras 2-3).

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Defendant-Appellant: Argued that the initial traffic stop violated the Fourth Amendment and Article II, Section 10 of the New Mexico Constitution due to lack of reasonable suspicion, contending that his conduct did not create an unsafe driving condition and thus did not violate Section 66-7-317(A) (para 3).
  • Plaintiff-Appellee (State): Contended that Section 66-7-317(A) does not require a motorist’s lane departure to affect other traffic to constitute a violation. Alternatively, argued that Officer Sedillos made an objectively reasonable mistake of law in believing that the Defendant violated Section 66-7-317(A), despite the lack of vehicles in the immediate vicinity (para 7).

Legal Issues

  • Whether the traffic stop of the Defendant was supported by reasonable suspicion under the Fourth Amendment and Article II, Section 10 of the New Mexico Constitution (para 3).
  • Whether a motorist’s lane departure must unsafely impact nearby vehicles to constitute a violation of Section 66-7-317(A) (para 7).

Disposition

  • The district court’s order denying the Defendant’s motion to suppress evidence obtained from the traffic stop was affirmed (para 18).

Reasons

  • The Court, led by Judge Vanzi with Judge Attrep concurring and Judge Ives specially concurring, held that the district court did not err in denying the Defendant’s motion to suppress. The Court found substantial evidence supporting the district court’s factual findings, including Officer Sedillos’s testimony and the dash cam video, and applied a de novo review to determine that reasonable suspicion existed for the traffic stop. The Court concluded that it was objectively reasonable for Officer Sedillos to believe that the Defendant violated Section 66-7-317(A) despite the Defendant’s conduct not immediately endangering other motorists. The Court declined to definitively interpret Section 66-7-317(A) due to the inadequacy of briefing on statutory construction but noted that the statute does not specify that lane departure must unsafely affect other traffic to constitute a violation. The Court also referenced the mistake of law doctrine, stating that a stop may be premised on an officer’s objectively reasonable mistake of law (paras 5-17).
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