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 Officer Johnston for riding a motorcycle without eye protection and with expired registration. During the stop, the Defendant admitted to not having a license and became noticeably nervous. Officer Johnston observed a knife clipped to the Defendant's pocket and initiated a pat-down search for officer safety, during which the Defendant's behavior escalated in nervousness. The search led to the Defendant's arrest for resisting, evading, or obstructing an officer after he failed to comply with instructions during the pat-down (paras 3-7).

Procedural History

• Appeal from the District Court of San Juan County, John A. Dean Jr., District Judge.

Parties' Submissions

• Defendant-Appellant: Argued that the pat-down search was conducted without reasonable suspicion of him being armed and dangerous and that the officer lacked probable cause to arrest him for resisting arrest (para 1).
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the officer’s pat-down search of the Defendant was supported by reasonable suspicion that he was armed and presently dangerous.
• Whether there was probable cause to arrest the Defendant for resisting, evading, or obstructing an officer (paras 8, 12).

Disposition

• The court affirmed the district court’s denial of the Defendant’s motion to suppress and affirmed the Defendant’s conviction (paras 1, 16).

Reasons

• Per M. Monica Zamora, J. (Jonathan B. Sutin, J., and Henry M. Bohnhoff, J., concurring), the court found substantial evidence supporting the district court's conclusions. It was determined that the officer had reasonable suspicion for the pat-down search based on the Defendant's possession of a knife and his nervous demeanor. The court also concluded that the officer had probable cause to arrest the Defendant for resisting arrest due to the Defendant's failure to comply with instructions during the pat-down search. The court emphasized the balance between officer safety and individual rights, noting that the officer's actions were justified under the circumstances to ensure safety without fear of violence. The court deferred to the officer's judgment, given the reasonable belief that the Defendant might be armed and dangerous and the Defendant's erratic behavior during the interaction (paras 8-15).