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 case involves the Defendant-Appellee, Larry Jeromy Keding, who was questioned by a police officer on the side of the road. The questioning led to the suppression of evidence obtained during this interaction, which was challenged by the State.
Procedural History
- APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY, Fernando Macias, District Judge: The district court granted in part Keding's motion to suppress evidence obtained while he was questioned by a police officer on the side of the road.
Parties' Submissions
- Appellant (State of New Mexico): Argued that the district court erred in suppressing the evidence based on a claimed Miranda violation, asserting that although Keding was detained for Fourth Amendment purposes, he was not in custody for purposes of Miranda and the Fifth Amendment.
- Appellee (Larry Jeromy Keding): In his memoranda in opposition, Keding argued that the suppression was warranted due to a Miranda violation and also contended that the officer lacked reasonable suspicion to detain him.
Legal Issues
- Whether the district court erred in suppressing evidence based on a claimed Miranda violation.
- Whether the officer had reasonable suspicion to detain Keding sufficient to justify the brief detention.
Disposition
- The Court of Appeals reversed the district court's order granting in part Keding's motion to suppress evidence.
Reasons
-
Per Timothy L. Garcia, J. (Celia Foy Castillo, Chief Judge, and Jonathan B. Sutin, Judge, concurring): The Court concluded that Keding was not in custody for purposes of Miranda during the roadside questioning, aligning with precedent that such a scenario does not rise to the level of custody requiring Miranda warnings. Furthermore, the Court found that the officer had reasonable suspicion to detain Keding based on the observation of a hand-to-hand cash transaction, sufficient to support a brief detention for investigation. The Court was not persuaded by Keding's arguments in his memoranda in opposition and, therefore, reversed the district court's suppression order.
You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.