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

• On July 2, 2012, an Albuquerque Police Officer observed the Defendant failing to stop at a stop sign and subsequently pulled her over. During the stop, the officer detected a strong odor of alcohol from the Defendant and conducted a horizontal gaze nystagmus (HGN) test, which led to her arrest and charges for driving under the influence (DWI), a stop sign violation, and having no proof of insurance (paras 2-3).

Procedural History

• District Court of Bernalillo County: The metropolitan court denied the Defendant's motion to suppress evidence on the grounds of pretext, leading to a conditional guilty plea with the right to appeal the denial of her motion to suppress based on pretext (para 1).
• Court of Appeals of New Mexico: Affirmed the metropolitan court's decision (para 25).

Parties' Submissions

• Defendant-Appellant: Argued that the traffic stop was pretextual, the location of the stop functioned as a de facto sobriety checkpoint, and the officer impermissibly expanded the scope of the original stop (para 9).
• Plaintiff-Appellee: Contended that the stop was justified based on the Defendant's failure to stop at a stop sign, and the subsequent actions taken by the officer were within the scope of standard police practices (paras 10-16).

Legal Issues

• Whether the traffic stop was pretextual.
• Whether the location of the stop functioned as a de facto sobriety checkpoint.
• Whether the officer impermissibly expanded the scope of the original stop.

Disposition

• The Court of Appeals affirmed the metropolitan court's decision, holding that the stop was not pretextual and declining to address the issues of the de facto sobriety checkpoint and the expansion of the scope of the stop due to the Defendant's failure to reserve her right to appeal these issues (paras 21-23).

Reasons

• Per JULIE J. VARGAS, Judge (LINDA M. VANZI, Chief Judge, and MICHAEL E. VIGIL, Judge concurring):
  The Court found substantial evidence supporting the metropolitan court's factual findings, including the officer's observation of the Defendant's traffic violation, which provided reasonable suspicion for the stop (paras 10-12).
  The Court concluded that the Defendant did not meet her burden of proving that the stop was pretextual, as the totality of circumstances, including the officer's compliance with standard practices and the immediate cause for the stop, did not indicate an unrelated motive unsupported by reasonable suspicion (paras 13-16).
  The Court distinguished this case from State v. Deleon, noting that the Defendant did not present sufficient evidence to establish a pattern of behavior by the officer that would indicate a pretextual stop (paras 17-20).
  The Court declined to address the issues of the de facto sobriety checkpoint and the expansion of the scope of the stop, as the Defendant did not reserve her right to appeal these issues in her conditional guilty plea (paras 21-23).