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

• Julio Marquez was arrested for DWI after failing to stop at a stop sign and showing signs of intoxication during a traffic stop by a Santa Fe Police Department officer. The officer initiated the stop after observing Marquez make a wide right turn without slowing down or stopping. Subsequent tests revealed Marquez had a blood-alcohol concentration of 0.09 percent. Marquez was charged with Careless Driving and DWI under the Santa Fe City Code. After a trial in municipal court, Marquez was found guilty of both charges and appealed for a de novo trial in district court. During the district court trial, the court sua sponte suppressed all evidence from the DWI investigation, leading to the dismissal of the DWI charge but upholding the Careless Driving conviction (paras 3-11).

Procedural History

• Municipal Court: Marquez was found guilty of Careless Driving and DWI.
• District Court: After a de novo trial, the court suppressed evidence from the DWI investigation and dismissed the DWI charge but upheld the Careless Driving conviction.

Parties' Submissions

• City: Argued that the evidence obtained during the DWI investigation was lawful and should not be suppressed.
• Marquez: Initially did not move to suppress evidence from the DWI investigation but later highlighted discrepancies between the officer's testimony and the video recording of the traffic stop to challenge the DWI charge.

Legal Issues

• Whether the district court erred in sua sponte suppressing all evidence from the DWI investigation and dismissing the DWI charge against Marquez.
• Whether constitutional double jeopardy principles bar the City from retrying Marquez for the DWI charge.

Disposition

• The Supreme Court dismissed the City's appeal based on double jeopardy principles, affirming the district court's order that suppressed evidence from the DWI investigation and dismissed the DWI charge (para 28).

Reasons

• The Supreme Court, with Justice Patricio M. Serna authoring the opinion, held that the district court's suppression of evidence and subsequent dismissal of the DWI charge functioned as an acquittal, thereby barring the City's appeal on double jeopardy grounds. The Court emphasized the need for suppression issues to be adjudicated prior to trial, absent good cause, to avoid unintended consequences such as the nullification of appeal rights due to double jeopardy protections. The Court clarified and expanded procedural rules to require that motions to suppress be filed before trial and adjudicated before trial, absent good cause. This directive aims to ensure that suppression orders are not immune from appellate review and to protect the prosecution's ability to appeal suppression rulings (paras 12-28).