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Facts

  • The case involves the Defendant's appeal from convictions for DWI and failure to maintain traffic lane. The convictions stemmed from an incident where Officer Chavez observed the Defendant's vehicle straddling the lane divider between the left-hand lane and turn bay on two separate occasions. Based on these observations, Officer Chavez initiated a traffic stop for violation of the Albuquerque City Code Section 8-2-1-42, which prohibits failing to keep a vehicle within the boundaries of a marked traffic lane except under specific lawful conditions (paras 3-4).

Procedural History

  • District Court of Bernalillo County, Stan Whitaker, District Judge: Affirmed the Defendant's convictions for DWI and for failure to maintain traffic lane following an on-record appeal from her jury trial conviction in metropolitan court (para 1).

Parties' Submissions

  • Defendant-Appellant: Argued that Officer Chavez lacked reasonable suspicion to support the traffic stop due to a mistake of law, asserting that the actions were either lawful attempts to move into a turn lane or necessitated by road conditions such as ice. The Defendant also contended that the lane changes did not present a safety hazard or affect other traffic, which should be a consideration under the ordinance (paras 2, 5-6).
  • Plaintiff-Appellee (State of New Mexico): Maintained that the traffic stop was justified based on the Defendant's violation of the failure to maintain lane ordinance, as observed by Officer Chavez. The State argued that the Defendant's vehicle straddling the lane divider constituted a violation of the Albuquerque City Code Section 8-2-1-42, regardless of the Defendant's intentions or the presence of any safety hazard (paras 3-4, 6).

Legal Issues

  • Whether Officer Chavez had reasonable suspicion to support the traffic stop based on the Defendant's alleged violation of the failure to maintain lane ordinance.
  • Whether the Defendant's actions constituted a violation of the Albuquerque City Code Section 8-2-1-42, considering the Defendant's arguments regarding lawful turning movements and road conditions.
  • Whether a safety hazard or effect on other traffic is required to constitute a violation of the failure to maintain lane ordinance (paras 2, 5-6).

Disposition

  • The Court of Appeals of New Mexico affirmed the district court’s judgment, upholding the Defendant's convictions for DWI and for failure to maintain traffic lane (para 7).

Reasons

  • Per LINDA M. VANZI, Judge (MICHAEL D. BUSTAMANTE, Judge, TIMOTHY L. GARCIA, Judge concurring): The Court found that Officer Chavez's observations of the Defendant's vehicle straddling the lane divider on two occasions provided sufficient basis for the traffic stop under the Albuquerque City Code Section 8-2-1-42. The Court rejected the Defendant's arguments that her actions were lawful attempts to move into a turn lane or necessitated by road conditions, stating that these were matters for the fact finder to determine. Furthermore, the Court clarified that the ordinance does not require a safety hazard or effect on other traffic to constitute a violation, thus Officer Chavez did not make a mistake of law in stopping the Defendant based on the observed lane violations. The Court's decision was based on the plain language of the ordinance and established principles of statutory interpretation (paras 3-6).
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