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

• A group of motorcyclists was struck by a truck driven by the Defendant, resulting in several injuries and one fatality. The Defendant fled the scene with passengers. Deputies entered the Defendant's home without a warrant, leading to his arrest and charges including homicide by vehicle and aggravated DWI. The Defendant's blood alcohol content was found to be 0.14 (paras 2-5).

Procedural History

• Appeal from the District Court of Rio Arriba County, Mary Marlowe-Sommer, District Judge.
• Certiorari Granted, August 7, 2015, No. S-1-SC-35386.

Parties' Submissions

• Defendant-Appellant: Argued that the deputies’ warrantless entry into his home violated the Fourth Amendment to the United States Constitution and Article II, Section 10 of the New Mexico Constitution, thereby contesting the legality of the evidence obtained post-entry (para 6).
• Plaintiff-Appellee: Justified the deputies' warrantless entry under the emergency assistance doctrine, arguing it was necessary for the protection of life or property (para 6).

Legal Issues

• Whether the district court erred in determining that the emergency assistance doctrine justified the warrantless entry by deputies into the Defendant's residence (para 1).
• Whether sufficient evidence supported the Defendant's conviction for causing great bodily injury by vehicle (para 15).

Disposition

• The court reversed the district court’s denial of the Defendant's motion to suppress and remanded for proceedings consistent with the opinion (para 20).

Reasons

• The court, led by Judge Cynthia A. Fry with Judges James J. Wechsler and Roderick Kennedy concurring, found that the deputies did not have reasonable grounds to believe that an emergency existed requiring their immediate aid, thus the warrantless entry was unjustified. The court applied the three-part test from State v. Ryon, focusing on the lack of reasonable grounds to believe an emergency was at hand and the deputies' primary motivation not being to arrest and seize evidence. The court concluded that the State failed to meet its burden to justify the warrantless entry under the emergency assistance doctrine. Regarding the sufficiency of the evidence for the conviction of causing great bodily injury by vehicle, the court found that the evidence was sufficient to support the conviction, meaning retrial on this charge is not barred (paras 7-19).