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 September 29, 2015, Officer Kyle Graham of the Alamogordo Police Department, while on patrol, initiated a traffic stop on a vehicle driven by Defendant James Tyrone Manning due to expired registration. During the stop, Officer Graham discovered that Manning had a revoked license with an arrest clause. Upon arresting Manning, Officer Graham found a container with methamphetamine near him, which Manning denied owning. Further search revealed more methamphetamine and drug paraphernalia in Manning's vehicle. Manning was subsequently indicted on multiple charges, including trafficking methamphetamine (para 2-5).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant-Appellant: Argued that the traffic stop was pretextual, lacking reasonable suspicion, and that the evidence obtained should be suppressed. Contended that the stop was motivated by his race, not the vehicle's expired registration. Also argued that there was insufficient evidence for the trafficking methamphetamine conviction and challenged the sentence enhancement for the trafficking conviction (paras 6-7, 9, 18-19, 24).
- Plaintiff-Appellee (State of New Mexico): Argued that there was reasonable suspicion for the initial stop due to the expired registration, thus justifying the stop and subsequent evidence seizure. Contended that the stop was not pretextual and was part of routine enforcement of motor vehicle laws. Also argued that substantial evidence supported the trafficking conviction and that the sentence enhancement was properly applied (paras 6-7, 10-12, 18-19, 24).
Legal Issues
- Whether the traffic stop was pretextual and lacked reasonable suspicion, thereby necessitating the suppression of evidence obtained during the stop.
- Whether there was substantial evidence to support the conviction for trafficking methamphetamine.
- Whether the sentence enhancement for the trafficking conviction was properly applied (paras 9, 18, 24).
Disposition
- The Court of Appeals affirmed the district court's denial of Defendant's motion to suppress, the conviction for trafficking methamphetamine, and the sentence enhancement (para 1, 17, 23, 30).
Reasons
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BOGARDUS, Judge (VARGAS, Judge and HENDERSON, Judge concurring): The court found that the traffic stop was supported by reasonable suspicion due to the expired registration and was not pretextual. The defendant failed to meet the burden of proving the stop was motivated by pretext. Substantial evidence supported the conviction for trafficking methamphetamine, including the defendant's control over the substance and intent to distribute. The sentence enhancement was properly applied, as the statutes for the current and prior offenses required the same knowledge or intent, making the prior offense applicable for enhancement purposes. The court also found no violation of constitutional rights regarding the sentence enhancement (paras 9-17, 18-23, 24-29).
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