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 case involves the Defendant, Steven Trujeque, who was convicted for driving while under the influence of intoxicating liquor (first offense). The conviction followed an incident where the Defendant was detained in handcuffs in the back of a police car after exhibiting an argumentative and aggressive demeanor when approached by an officer. The officer had been dispatched based on a Priority 1, 911 call reporting an individual repeatedly knocking on the doors of his ex-girlfriend’s home, leading to an investigation for potential criminal trespass or harassment (paras 2-4).

Procedural History

• District Court of Bernalillo County, Stan Whitaker, District Judge: Affirmed the Defendant's conviction by conditional plea for driving while under the influence of intoxicating liquor (first offense).

Parties' Submissions

• Defendant-Appellant: Argued that the detention in handcuffs in the back of the police car was unreasonable because the State did not demonstrate its necessity for officer safety (para 2).
• Plaintiff-Appellee: Supported the district court's memorandum opinion affirming the conviction, emphasizing the reasonableness of the detention based on the Defendant's demeanor and the need for the officer to investigate the situation (paras 2-3).

Legal Issues

• Whether the Defendant's detention in handcuffs in the back of a police car was unreasonable due to a lack of necessity for officer safety.
• Whether the trial court committed fundamental error in failing to find that the delay between when the Defendant was handcuffed and placed in the police car and when the Defendant was transported constituted a de facto arrest.

Disposition

• The Court of Appeals affirmed the Defendant’s conviction (para 8).

Reasons

• The Court, with Judge Timothy L. Garcia authoring the memorandum opinion and Judges Michael D. Bustamante and Roderick T. Kennedy concurring, held that the detention was reasonable. The decision was based on the Defendant's argumentative and aggressive demeanor, the officer's need to investigate a potential criminal trespass or harassment, and the details provided in the 911 call that led to the officer's dispatch. The Court found that the officer had a reasonable, particularized suspicion that the Defendant was involved in criminal activity, justifying the investigatory detention. The Court also addressed the Defendant's argument regarding the alleged fundamental error related to the delay in his transport after being detained, concluding that the Defendant did not demonstrate circumstances that would constitute fundamental error under the doctrine. The Court's decision was grounded in established legal principles regarding investigatory detention and fundamental error (paras 2-7).