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 January 12, 2012, Deputy Daniel Vasquez arrested Wesley Davis for operating a motorcycle with a revoked license. During the arrest, Deputy Vasquez searched Davis's backpack, which was placed on a car in an open-air carport, and found marijuana. Davis was charged with distribution of marijuana. He filed a motion to suppress the marijuana found, arguing the search was invalid. The district court denied the motion, concluding the search was a valid inventory search (paras 2-8).

Procedural History

• Court of Appeals: Reversed the district court's order, concluding the warrantless search was not a valid inventory search (para 9).
• District Court: Denied Davis's motion to suppress, finding the search a valid inventory search (para 8).

Parties' Submissions

• Plaintiff-Petitioner (State of New Mexico): Argued that the inventory search of Davis's backpack was valid because it was in Davis's possession at the time of arrest and conducted according to the Sheriff’s Department policy (paras 10-32).
• Defendant-Respondent (Wesley Davis): Contended that the inventory search was invalid as the backpack was not on his person or in his physical possession at the time of arrest and was taken from his private property without a warrant (paras 10-32).

Legal Issues

• Whether the inventory search of Davis's backpack was valid under the inventory search exception to the warrant requirement (para 9).
• Whether Davis possessed the backpack at the time of arrest for the purposes of the inventory search exception (paras 13-22).
• Whether the inventory search policy of the Sheriff’s Department was properly applied in this case (paras 27-30).

Disposition

• The Supreme Court of the State of New Mexico reversed the Court of Appeals, affirmed the district court’s order denying Davis’s motion to suppress, and remanded the matter to the district court for further proceedings consistent with the opinion (para 33).

Reasons

• The Supreme Court, per Chief Justice Nakamura, with Justices Maes, Chávez, Daniels, and Vigil concurring, held that:
  The inventory search of Davis's backpack was valid as Davis did possess the backpack at the time of arrest in the broader sense required for inventory searches. The search was justified in light of the core purposes behind the inventory search exception, which include protecting the arrestee’s property and the police from liability (paras 16-22).
  The Court of Appeals erred in concluding that the backpack was not in Davis's possession at the time of arrest based on a restrictive definition of "possession." The Supreme Court embraced a broader definition, considering any object that the defendant loses control over as a consequence of arrest and where that loss of control gives rise to the possibility that the object might be lost, stolen, or destroyed (paras 17-18).
  The inventory search was conducted in conformity with established police regulations, and the search was reasonable. The Sheriff’s Department’s policy mandates inventorying any belongings in a person’s possession at the time of an arrest, which includes items rendered unsecure by the arrest (paras 27-30).
  The Court of Appeals' concerns regarding the seizure of the backpack from Davis's private property were addressed by distinguishing the facts of the case from a blanket prohibition against inventory searches on private property. The search was deemed an appropriate exercise of community caretaking to protect Davis’s possessions (paras 23-25).