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Citations - New Mexico Laws and Court Rules
Rule Set 12 - Rules of Appellate Procedure - cited by 9,535 documents

Decision Content

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 State filed indictments against Raymundo Maso and Sara Gonzales for drug-related offenses after a search warrant for their shared apartment revealed incriminating evidence. Both defendants filed a motion to suppress the evidence, which the district court granted, deeming the search warrant invalid due to insufficient specific facts to establish probable cause (para 4).

Procedural History

  • State v. Maso, No. 29,842, slip op. (N.M. Ct. App. April 14, 2010) (non-precedential), cert. denied, S. Ct. No. 32,398 (August 25, 2010): The Court of Appeals reversed the district court's suppression order and remanded for further proceedings.
  • State v. Gonzales, No. 29,843, slip op. (N.M. Ct. App. December 9, 2011) (non-precedential), cert. granted, S. Ct. No. 33,376 (February 16, 2012): The Court of Appeals affirmed the district court's suppression order.

Parties' Submissions

  • State: Argued against the district court's order suppressing evidence, asserting that the search warrant was valid and that the evidence obtained should not be suppressed.
  • Defendant-Respondent (Gonzales): Joined the motion to suppress evidence, arguing that the search warrant was invalid due to lack of sufficient specific facts to establish probable cause.

Legal Issues

  • Whether the district court erred in granting the motion to suppress evidence based on the invalidity of the search warrant under the United States or New Mexico Constitution.

Disposition

  • The Supreme Court of New Mexico quashed the writ of certiorari, leaving the Court of Appeals' decision to affirm the suppression order in place (para 6).

Reasons

  • The Supreme Court expressed concern over the procedural history of the case and a related case, noting the District Attorney's failure to comply with Rule 12-208 NMRA, which led to the issuance of contradictory opinions by the Court of Appeals on related appeals. This failure wasted the appellate courts' and parties' time and complicated the administration of justice. The Supreme Court emphasized the importance of adhering to the Rules of Appellate Procedure to prevent such procedural conflicts. Despite the procedural issues, the Supreme Court agreed with the Court of Appeals' reasoning and conclusion in this case, leading to the quashing of the writ of certiorari. The decision also highlighted the dismissal of charges against both Gonzales and Maso, alleviating concerns about inconsistent application of the law for the co-defendants (paras 1-13).
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