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

• One evening in 2009, after hearing a collision outside, Andrew Ayala witnessed the Defendant, Gregg Crocco, enter his house uninvited, appearing intoxicated. Crocco left Ayala's house, drove erratically, and was later found by police in another house, showing signs of intoxication. Crocco was arrested and charged with aggravated DWI. The police entry into the house where Crocco was found was without a warrant, raising questions about the legality of the evidence obtained (paras 2-5).

Procedural History

• District Court: Found Defendant guilty of aggravated DWI, noting the lack of a motion to suppress evidence obtained from the warrantless entry (para 7).
• Court of Appeals, State v. Crocco, 2013-NMCA-033: Reversed the district court's decision, concluding Defendant made a prima facie showing of ineffective assistance of counsel due to failure to file a motion to suppress evidence (para 9).

Parties' Submissions

• Plaintiff-Petitioner (State of New Mexico): Argued that the record failed to establish a prima facie case of ineffective assistance of counsel because Defendant did not have standing to challenge the warrantless entry and the entry was lawful under emergency assistance and exigent circumstances exceptions (para 10).
• Defendant-Respondent (Gregg Crocco): Claimed ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the warrantless entry, arguing he had a reasonable expectation of privacy in the house entered by police (paras 1, 8).

Legal Issues

• Whether the Defendant had a reasonable expectation of privacy in the house entered by police without a warrant, granting him standing to challenge the search.
• Whether the Defendant's counsel provided ineffective assistance by failing to file a motion to suppress evidence obtained from the warrantless entry (paras 12-24).

Disposition

• The Supreme Court of the State of New Mexico reversed the Court of Appeals' decision and affirmed the judgment of the district court (para 25).

Reasons

• DANIELS, Justice, for a unanimous court:
  The Court held that the Defendant did not establish a prima facie case of ineffective assistance of counsel because the record did not demonstrate that he had a reasonable expectation of privacy in the house where he was found by police. The Court emphasized that Fourth Amendment rights are personal and cannot be vicariously asserted. The Defendant's mere presence in the house, without evidence of permission to be there, did not establish a legitimate expectation of privacy. The Court also noted that the Defendant's failure to respond to police questions about his permission to be in the house and the absence of testimony from the homeowner or other evidence of permission further weakened his claim. The Court concluded that without evidence of a constitutionally protected privacy interest, it was unnecessary to address the legality of the warrantless entry. The Court suggested that if facts beyond the record could establish a legitimate claim of ineffective assistance of counsel, the Defendant could pursue it in a habeas corpus proceeding where a more adequate factual record could be developed (paras 12-24).