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 Defendant was sentenced for possession of a controlled substance and drug paraphernalia found in a duffel bag during a search warrant execution at a residence. The warrant targeted the residence and its owner for selling methamphetamine, but the Defendant, not named in the affidavit, claimed the duffel bag containing the substances belonged to him (paras 2-5, 8).
Procedural History
- Appeal from the District Court of Curry County, Drew D. Tatum, District Judge: The district court denied the Defendant's motion to suppress evidence found in his duffel bag, leading to his conviction.
Parties' Submissions
- Defendant-Appellant: Argued that the search warrant, while valid for the residence and its owner, did not extend to his personal property, specifically the duffel bag, as it did not establish probable cause for searching his belongings. Additionally, contended that even if the search was conducted in good faith, the evidence should be suppressed as New Mexico does not recognize the good faith exception to the exclusionary rule (paras 10, 20).
- Plaintiff-Appellee: [Not applicable or not found]
Legal Issues
- Whether a valid search warrant for a residence extends to the search and seizure of personal property belonging to a non-resident found on the premises.
- Whether the good faith exception to the exclusionary rule applies in New Mexico for evidence obtained from a search deemed outside the scope of a valid warrant.
Disposition
- The Court of Appeals affirmed the district court's denial of the Defendant's motion to suppress the evidence found in his duffel bag (para 24).
Reasons
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Per Michael D. Bustamante, J. (James J. Wechsler, J., Cynthia A. Fry, J., concurring): The court held that the search warrant did extend to the duffel bag found in the residence, as there was no indication at the time of the search that the bag belonged to someone other than the residence owner. The court distinguished this case from precedent by noting that the officers had probable cause to search the bag as it was a logical place to find the items listed in the warrant. The court also noted that the Defendant's argument regarding the good faith exception was immaterial since the search of the duffel bag was deemed lawful under Article II, Section 10 of the New Mexico Constitution, thus upholding the search's validity and the evidence's admissibility (paras 1, 13-19, 23).
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