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 followed by an arresting officer and observed making a wide right turn, during which the officer believed the Defendant's vehicle crossed into another lane, violating the Roadways Violation statute. Upon stopping the Defendant's truck, the officer noticed signs of alcohol influence, leading to the Defendant's arrest and charges for a Roadways Violation and driving under the influence (DWI).

Procedural History

• Municipal court: Defendant was convicted of DWI and a Roadways Violation.
• District Court of San Juan County: On appeal, the court conducted a trial de novo, denied the Defendant's motion to suppress evidence from the traffic stop, found the Defendant guilty of DWI, but not guilty of the Roadways Violation.

Parties' Submissions

• Defendant-Appellant: Argued that the traffic stop lacked reasonable suspicion as it was based on an erroneous application of the Roadways Violation statute and challenged the constitutionality of the stop as pretextual. Contended that the horizontal gaze and nystagmus field test should not be used to determine probable cause for arrest.
• Plaintiff-Appellee (City of Farmington): Contended that the officer had reasonable suspicion to stop the Defendant's vehicle based on the observed traffic violation and argued that the Defendant did not preserve the mistake of law argument for appellate review.

Legal Issues

• Whether the officer had reasonable suspicion to stop the Defendant's vehicle based on the observed traffic violation.
• Whether the Defendant preserved the mistake of law argument for appellate review.

Disposition

• The Court of Appeals reversed the district court’s denial of the motion to suppress evidence obtained from the traffic stop, holding that the officer lacked reasonable suspicion for the stop. The case was remanded to the district court with instructions to dismiss the DWI conviction.

Reasons

• TIMOTHY L. GARCIA, Judge (JONATHAN B. SUTIN, Judge, CYNTHIA A. FRY, Judge concurring): The court concluded that the Defendant properly preserved his mistake of law argument for review, as the crux of his argument was that the officer’s interpretation of the Roadways Violation statute was incorrect (para BACKGROUND). The court found that conduct based on a mistake of law cannot create the reasonable suspicion needed for a traffic stop unless other specific and articulable facts support reasonable suspicion (para C). The court determined that the officer's belief that the Defendant's vehicle crossing lane lines constituted a violation was a mistake of law, as the statute requires that a vehicle must be driven as nearly as practicable entirely within a single lane and shall not be moved from such lane until the driver has first ascertained that such movement can be made with safety (para C). The court held that the officer did not have reasonable suspicion to stop and detain the Defendant because the Defendant did not commit a per se violation of the Roadways Violation statute, and no other factual basis justified the need for an investigatory stop (para C).