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 Defendant was stopped by an officer for a traffic violation based on the belief that she violated NMSA 1978, § 66-7-317(A), which requires a vehicle to be driven within a single lane and not change lanes until it can be done safely. The officer's observations led to suspicions of the Defendant's impairment due to erratic driving, prompting further investigation.

Procedural History

• Appeal from the District Court of San Juan County, Karen L. Townsend, District Judge: The district court denied the Defendant's motion to suppress evidence and issued a mandate to the magistrate court either after thirty-one days or upon final disposition of an appeal to this Court.

Parties' Submissions

• Defendant-Appellant: Argued that the officer lacked reasonable suspicion to stop her for a violation of NMSA 1978, § 66-7-317(A) and that the traffic stop was premised on a mistake of law.
• Plaintiff-Appellee (State of New Mexico): Contended that the officer had reasonable suspicion to stop the Defendant due to erratic driving, suggesting possible impairment, and that this justified the traffic stop independently of the initially suspected traffic violation.

Legal Issues

• Whether the officer had reasonable suspicion to stop the Defendant based on observed erratic driving, notwithstanding the initial premise for the traffic stop being a potential mistake of law.

Disposition

• The Court of Appeals affirmed the district court's denial of the Defendant's motion to suppress.

Reasons

• Per Cynthia A. Fry, J. (Michael E. Vigil, J., M. Monica Zamora, J., concurring): The Court found that the officer's initial belief regarding the traffic violation was not critical to the legality of the stop. Instead, the officer's observations provided an alternative basis for reasonable suspicion—erratic driving indicative of possible impairment. The Court emphasized that the objective evidence supported a reasonable belief of impairment that warranted further investigation, aligning with precedent that erratic driving can justify a traffic stop for suspected DWI. The Court's decision was based on viewing the evidence in the light most favorable to the district court's ruling, affirming the denial of the motion to suppress based on sufficient erratic driving to support reasonable suspicion of impairment (paras 2-4).