fact-specific inquiry (New Mexico) · Go Syfert
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fact-specific inquiry in New Mexico

35 New Mexico opinions name it 2 courts 1998–2025 7 in the last five years

The cases below were cited by New Mexico courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (27)

CaseFollowedCited
State v. SMILEgreen
nmctapp · 2009 · cited in 3 New Mexico opinions naming this issue, 2011–2014
2 sentences

2014See, e.g., Smile, 2009-NMCA-064, ¶ 27 .

2014See, e.g., Smile, 2009-NMCA-064, ¶ 27 .

33
State v. Olivasgreen
nmctapp · 2011 · cited in 6 New Mexico opinions naming this issue, 2012–2021
2 sentences

2021Rather, we consider how “a reasonable man in the suspect’s position would have understood his situation.” Id. (internal quotation marks and citation omitted). {20} In the event that there is no formal arrest prior to questioning, “our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.” State v. Olivas, 2011-NMCA-030, ¶ 10 , 149 N.M. 498 , 252 P.3d 722 .

2021Rather, we consider how “a reasonable man in the suspect’s position would have understood his situation.” Id. (internal quotation marks and citation omitted). {20} In the event that there is no formal arrest prior to questioning, “our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.” State v. Olivas, 2011-NMCA-030, ¶ 10 , 149 N.M. 498 , 252 P.3d 722 .

26
State v. Arredondogreen
nmctapp · 1997 · cited in 3 New Mexico opinions naming this issue, 2004–2007
2 sentences

2007See § 30-7-2.1(A)(5); Arredondo, 1997-NMCA-081, ¶28 (eschewing bright-line rules and requiring a fact-specific inquiry into the reasonableness of a search under Article II, Section 10). {34} We hold that the State failed to justify the warrantless search and seizure related to the weapons, and that suppression of the weapons, therefore, is affirmed.

2007See § 30-7-2.1(A)(5); Arredondo, 1997-NMCA-081, ¶ 28 (eschewing bright-line rules and requiring a fact-specific inquiry into the reasonableness of a search under Article II, Section 10). {34} We hold that the State failed to justify the warrantless search and seizure related to the weapons, and that suppression of the weapons, therefore, is affirmed.

23
Trinity Episcopal Church v. State Board of Tax Commissionersgreen
indtc · 1998 · cited in 2 New Mexico opinions naming this issue, 2014–2014
2 sentences

2014The Appropriate Inquiry Is Whether the Property’s Use Furthered the Exempt Purpose {21} Instead of adding a new fact-specific exception to the rule, we distill the various rules and exceptions governing exemptions to one overarching principle: “[T]he proper focus of any inquiry into the propriety of an exemption is whether the use of the property furthers exempt purposes.” Trinity Episcopal Church v. State Bd. of Tax Comm’rs, 694 N.E.2d 816, 818 (Ind. Tax Ct. 1998) (representing the source of authority for this proposition on which multiple Indiana cases have since relied); see also Congregati

2014The Appropriate Inquiry Is Whether the Property’s Use Furthered the Exempt Purpose {21} Instead of adding a new fact-specific exception to the rule, we distill the various rules and exceptions governing exemptions to one overarching principle: “[T]he proper focus of any inquiry into the propriety of an exemption is whether the use of the property furthers exempt purposes.” Trinity Episcopal Church v. State Bd. of Tax Comm’rs, 694 N.E.2d 816, 818 (Ind. Tax Ct. 1998) (representing the source of authority for this proposition on which multiple Indiana cases have since relied); see also Congregati

22
Congregation Machne Chaim, Inc. v. Kwakgreen
nyappdiv · 2004 · cited in 2 New Mexico opinions naming this issue, 2014–2014
2 sentences

2014The Appropriate Inquiry Is Whether the Property’s Use Furthered the Exempt Purpose {21} Instead of adding a new fact-specific exception to the rule, we distill the various rules and exceptions governing exemptions to one overarching principle: “[T]he proper focus of any inquiry into the propriety of an exemption is whether the use of the property furthers exempt purposes.” Trinity Episcopal Church v. State Bd. of Tax Comm’rs, 694 N.E.2d 816, 818 (Ind. Tax Ct. 1998) (representing the source of authority for this proposition on which multiple Indiana cases have since relied); see also Congregati

2014The Appropriate Inquiry Is Whether the Property’s Use Furthered the Exempt Purpose {21} Instead of adding a new fact-specific exception to the rule, we distill the various rules and exceptions governing exemptions to one overarching principle: “[T]he proper focus of any inquiry into the propriety of an exemption is whether the use of the property furthers exempt purposes.” Trinity Episcopal Church v. State Bd. of Tax Comm’rs, 694 N.E.2d 816, 818 (Ind. Tax Ct. 1998) (representing the source of authority for this proposition on which multiple Indiana cases have since relied); see also Congregati

22
State v. Munozgreen
nm · 1998 · cited in 3 New Mexico opinions naming this issue, 2009–2021
2 sentences

2021The following factors guide our inquiry: “the purpose, place, and length of interrogation[,] . . . the extent to which the defendant is confronted with evidence of guilt, the physical surroundings of the interrogation, the duration of the detention, and the degree of pressure applied to the defendant.” State v. Munoz, 1998-NMSC-048, ¶ 40 , 126 N.M. 535 , 972 P.2d 847 (internal quotation marks and citation omitted). {21} Defendant drove to the sheriff’s department on his own accord for the purpose of discussing the burglary of his trailer with Detective Babadi.

2021The following factors guide our inquiry: “the purpose, place, and length of interrogation[,] . . . the extent to which the defendant is confronted with evidence of guilt, the physical surroundings of the interrogation, the duration of the detention, and the degree of pressure applied to the defendant.” State v. Munoz, 1998-NMSC-048, ¶ 40 , 126 N.M. 535 , 972 P.2d 847 (internal quotation marks and citation omitted). {21} Defendant drove to the sheriff’s department on his own accord for the purpose of discussing the burglary of his trailer with Detective Babadi.

13
State v. Fernandezgreen
nmctapp · 2007 · cited in 2 New Mexico opinions naming this issue, 2009–2015
2 sentences

2015See State v. LaPietra, 2010-NMCA-009, ¶ 10 , 147 N.M. 569 , 226 P.3d 668 8 (holding that it is beyond a district court’s Foulenfont authority to dismiss charges 9 when an element of the offense involves a fact-specific inquiry that is within the 10 unique purview of the jury); see also State v. Fernandez, 2007-NMCA-091, ¶ 7 , 142 11 N.M. 231 , 164 P.3d 112 (concluding that it is well-settled law that a jury determines 12 whether an object is used as a “deadly weapon” because it is a fact-specific inquiry 13 and requires a case-by-case determination).

2015See State v. LaPietra, 2010-NMCA-009, ¶ 10 , 147 N.M. 569 , 226 P.3d 668 8 (holding that it is beyond a district court’s Foulenfont authority to dismiss charges 9 when an element of the offense involves a fact-specific inquiry that is within the 10 unique purview of the jury); see also State v. Fernandez, 2007-NMCA-091, ¶ 7 , 142 11 N.M. 231 , 164 P.3d 112 (concluding that it is well-settled law that a jury determines 12 whether an object is used as a “deadly weapon” because it is a fact-specific inquiry 13 and requires a case-by-case determination).

12
State v. Swisegreen
nm · 1983 · cited in 2 New Mexico opinions naming this issue, 2009–2012
2 sentences

2012State v. Swise, 100 N.M. 256, 258 , 669 P.2d 11 732, 734 (1983). 12 In a case such as this, where no formal arrest occurred prior to questioning by 13 law enforcement, we “engage in a fact-specific analysis of the totality of the 14 circumstances under which the questioning took place in order to decide whether the 15 custody requirement is met.” Olivas, 2011-NMCA-030, ¶ 10 .

2009State v. Swise, 100 N.M. 256, 258 , 669 P.2d 732, 734 (1983). {27} Determining whether an individual is in custody for purposes of Miranda requires a fact-specific analysis of the circumstances in which the questioning took place.

12
State v. Hermosillogreen
nmctapp · 2014 · cited in 1 New Mexico opinions naming this issue, 2025–2025
1 sentence

2025See State v. Hermosillo, 2014-NMCA-102, ¶ 11 , 336 P.3d 446 (“If no formal arrest occurred prior to questioning, our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.”). {6} Before the investigating officer arrived, civilian bystanders1 prevented Defendant from fleeing the scene of the accident.

11
Coleman v. District of Columbiagreen
cadc · 2015 · cited in 1 New Mexico opinions naming this issue, 2025–2025
1 sentence

2025See Coleman v. District of Columbia, 794 F.3d 49 , 59 16 (D.C.

11
Chevron Oil Co. v. Sutton Ex Rel. Suttongreen
nm · 1973 · cited in 1 New Mexico opinions naming this issue, 2021–2021
2 sentences

2021See, e.g., Chevron Oil Co. v. Sutton, 1973-NMSC-111 , ¶ 9, 85 N.M. 679 , 515 P.2d 1283 (“The apparent authority of an agent is to be determined by the acts of the principal . . . from statements, conduct, lack of ordinary care, or other manifestation of the principal’s consent, whereby third persons are justified in believing that the agent is acting within his authority” (emphasis added) (citation omitted)).

2021See, e.g., Chevron Oil Co. v. Sutton, 1973-NMSC-111 , ¶ 9, 85 N.M. 679 , 515 P.2d 1283 (“The apparent authority of an agent is to be determined by the acts of the principal . . . from statements, conduct, lack of ordinary care, or other manifestation of the principal’s consent, whereby third persons are justified in believing that the agent is acting within his authority” (emphasis added) (citation omitted)).

11
State v. Trujillogreen
nmctapp · 2012 · cited in 1 New Mexico opinions naming this issue, 2019–2019
1 sentence

2019See Trujillo, 2012-NMCA-112, ¶ 42 (noting that a “more complicated factual scenario” presents a fact-specific inquiry for the jury as to whether a restraint is incidental to another crime).

11
State v. Le Miergreen
nm · 2017 · cited in 1 New Mexico opinions naming this issue, 2018–2018
1 sentence

2018See Le Mier, 10 2017-NMSC-017, ¶ 25 (“When a court orders a party to provide discovery within a 11 given time frame, failure to comply with that order causes prejudice both to the 12 opposing party and to the court.”); see also Lewis, 2018-NMCA-019 , ¶ 14 (noting 13 that, under Le Mier, every discovery violation results in some level of prejudice). 14 Additionally, the discovery violation in this case was not discovered until the middle 15 of trial.

11
United States v. Ozbirngreen
ca10 · 1999 · cited in 1 New Mexico opinions naming this issue, 2017–2017
1 sentence

2017Instead, 17 the Tenth Circuit reiterated its holding in United States v. Gregory, 79 F.3d 973 , 1978 18 (10th Cir. 1996), that the statute’s “ ‘as nearly as practicable’ ” qualification 19 “require[s] a fact-specific inquiry into the particular circumstances present during the 20 incident in question to determine whether the driver could reasonably be expected to 21 maintain a straight course at that time in that vehicle on that roadway.” Alvarado, 430 22 F.3d at 1309; see United States v. Cline, 349 F.3d 1276, 1287 (10th Cir. 2003) 10 1 (stating that “the particular facts and circumstances of

11
United States v. Cline, Timothygreen
ca10 · 2003 · cited in 1 New Mexico opinions naming this issue, 2017–2017
1 sentence

2017Instead, 17 the Tenth Circuit reiterated its holding in United States v. Gregory, 79 F.3d 973 , 1978 18 (10th Cir. 1996), that the statute’s “ ‘as nearly as practicable’ ” qualification 19 “require[s] a fact-specific inquiry into the particular circumstances present during the 20 incident in question to determine whether the driver could reasonably be expected to 21 maintain a straight course at that time in that vehicle on that roadway.” Alvarado, 430 22 F.3d at 1309; see United States v. Cline, 349 F.3d 1276, 1287 (10th Cir. 2003) 10 1 (stating that “the particular facts and circumstances of

11
State v. LaPIETRAgreen
nmctapp · 2009 · cited in 1 New Mexico opinions naming this issue, 2015–2015
2 sentences

2015See State v. LaPietra, 2010-NMCA-009, ¶ 10 , 147 N.M. 569 , 226 P.3d 668 8 (holding that it is beyond a district court’s Foulenfont authority to dismiss charges 9 when an element of the offense involves a fact-specific inquiry that is within the 10 unique purview of the jury); see also State v. Fernandez, 2007-NMCA-091, ¶ 7 , 142 11 N.M. 231 , 164 P.3d 112 (concluding that it is well-settled law that a jury determines 12 whether an object is used as a “deadly weapon” because it is a fact-specific inquiry 13 and requires a case-by-case determination).

2015See State v. LaPietra, 2010-NMCA-009, ¶ 10 , 147 N.M. 569 , 226 P.3d 668 8 (holding that it is beyond a district court’s Foulenfont authority to dismiss charges 9 when an element of the offense involves a fact-specific inquiry that is within the 10 unique purview of the jury); see also State v. Fernandez, 2007-NMCA-091, ¶ 7 , 142 11 N.M. 231 , 164 P.3d 112 (concluding that it is well-settled law that a jury determines 12 whether an object is used as a “deadly weapon” because it is a fact-specific inquiry 13 and requires a case-by-case determination).

11
State v. Figueroagreen
nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., State v. Smile, 2009-NMCA-064, ¶ 27 , 146 N.M. 525 , 212 P.3d 413 , cert. quashed, 2010-NMCERT-006 , 148 N.M. 584 , 241 P.3d 182 .

11
State v. SMILEgreen
nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., State v. Smile, 2009-NMCA-064, ¶ 27 , 146 N.M. 525 , 212 P.3d 413 , cert. quashed, 2010-NMCERT-006 , 148 N.M. 584 , 241 P.3d 182 .

11
State v. Montoyagreen
nm · 2010 · cited in 1 New Mexico opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., State v. Smile, 2009-NMCA-064, ¶ 27 , 146 N.M. 525 , 212 P.3d 413 , cert. quashed, 2010-NMCERT-006 , 148 N.M. 584 , 241 P.3d 182 .

11
State v. Romerogreen
nmctapp · 2006 · cited in 1 New Mexico opinions naming this issue, 2009–2009
11
State v. Maresgreen
nmctapp · 1979 · cited in 1 New Mexico opinions naming this issue, 2009–2009
11
State v. Hugheygreen
nm · 2007 · cited in 1 New Mexico opinions naming this issue, 2009–2009
11
State v. Parksgreen
arizctapp · 2005 · cited in 1 New Mexico opinions naming this issue, 2006–2006
11
State v. Allengreen
ncctapp · 2005 · cited in 1 New Mexico opinions naming this issue, 2006–2006
11
State v. Wrightgreen
minn · 2005 · cited in 1 New Mexico opinions naming this issue, 2006–2006
11
Ohio v. Robinettegreen
scotus · 1996 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
Silva v. Stategreen
nm · 1987 · cited in 1 New Mexico opinions naming this issue, 1998–1998
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
State v. Duran green
nm · 2005
2 sentences

2025“This is a fact-specific inquiry that does not lend itself to bright-line rules.” State v. Duran, 2005- NMSC-034, ¶ 23, 138 N.M. 414 , 120 P.3d 836 (internal quotation marks and citation omitted), overruled on other grounds by Leyva, 2011-NMSC-009, ¶ 3 .

2025“This is a fact-specific inquiry that does not lend itself to bright-line rules.” State v. Duran, 2005- NMSC-034, ¶ 23, 138 N.M. 414 , 120 P.3d 836 (internal quotation marks and citation omitted), overruled on other grounds by Leyva, 2011-NMSC-009, ¶ 3 .

42010–2025
State v. Leyva green
nm · 2011
1 sentence

2025“This is a fact-specific inquiry that does not lend itself to bright-line rules.” State v. Duran, 2005- NMSC-034, ¶ 23, 138 N.M. 414 , 120 P.3d 836 (internal quotation marks and citation omitted), overruled on other grounds by Leyva, 2011-NMSC-009, ¶ 3 .

12025–2025
State Ex Rel. State Highway Department v. Kistler-Collister Co. green
nm · 1975
2 sentences

2021State Highway Dep’t v. Kistler-Collister Co., 1975-NMSC-039, ¶ 21 , 88 N.M. 221 , 539 P.2d 611 , for expenses or loss of business occasioned by the government’s road construction, a test that includes consideration of whether the government was “unreasonable, arbitrary or capricious.” They argue this test is suitable since both the 19Miller recognized that when a state is “under the necessity of making a choice” between injuries, [i]t would have been none the less a choice if . . . the state, by doing nothing, had permitted serious injury . . . to go on unchecked.

2021State Highway Dep’t v. Kistler-Collister Co., 1975-NMSC-039, ¶ 21 , 88 N.M. 221 , 539 P.2d 611 , for expenses or loss of business occasioned by the government’s road construction, a test that includes consideration of whether the government was “unreasonable, arbitrary or capricious.” They argue this test is suitable since both the 19Miller recognized that when a state is “under the necessity of making a choice” between injuries, [i]t would have been none the less a choice if . . . the state, by doing nothing, had permitted serious injury . . . to go on unchecked.

12021–2021
Trevizo v. Adams green
ca10 · 2006
1 sentence

2021Trevizo, 455 F.3d at 1162 .

12021–2021
State v. Wilson green
nmctapp · 2007
1 sentence

2021Rather, we consider how “a reasonable man in the suspect’s position would have understood his situation.” Id. (internal quotation marks and citation omitted). {20} In the event that there is no formal arrest prior to questioning, “our appellate courts engage in a fact-specific analysis of the totality of the circumstances under which the questioning took place in order to decide whether the custody requirement is met.” State v. Olivas, 2011-NMCA-030, ¶ 10 , 149 N.M. 498 , 252 P.3d 722 .

12021–2021
United States v. Paul Charleston Gregory green
ca10 · 1996
1 sentence

2017Instead, 17 the Tenth Circuit reiterated its holding in United States v. Gregory, 79 F.3d 973 , 1978 18 (10th Cir. 1996), that the statute’s “ ‘as nearly as practicable’ ” qualification 19 “require[s] a fact-specific inquiry into the particular circumstances present during the 20 incident in question to determine whether the driver could reasonably be expected to 21 maintain a straight course at that time in that vehicle on that roadway.” Alvarado, 430 22 F.3d at 1309; see United States v. Cline, 349 F.3d 1276, 1287 (10th Cir. 2003) 10 1 (stating that “the particular facts and circumstances of

12017–2017
Ettenson v. Burke green
nmctapp · 2000
1 sentence

2017This determination requires 15 that district courts undertake a fact-specific inquiry that examines “the motivating 16 forces” behind the inducement of the breach—specifically whether the breach 17 “serve[d the defendant’s] private interest with no benefit to the corporation.” Id. ¶ 18 18 (internal quotation marks and citation omitted). 37 1 {64} Only an officer or director of Wallen could have directed Montoya’s actions 2 or made decisions about delaying payments to vendors and closing the company as 3 described in the district court’s findings of fact.

12017–2017
State v. Wilson green
nm · 2010
1 sentence

2012Our Supreme Court has 16 identified factors to guide our inquiry, including “the purpose, place, and length of 17 interrogation, the extent to which the defendant [was] confronted with evidence of 18 guilt, the physical surroundings of the interrogation, the duration of the detention, and 27 1 the degree of pressure applied to the defendant.” Id. (alteration, internal quotation 2 marks, and citation omitted); Wilson, 2011-NMSC-001, ¶ 48 . 3 Defendant asserts that he was in custody at the time he was asked who the red 4 backpack belonged to and during the subsequent search of the backpack.

12012–2012
State v. Funderburg green
nm · 2008
2 sentences

2012Determining whether reasonable suspicion exists “is a fact-specific inquiry that does not lend itself to bright-line rules.” Id. “[RJeasonable suspicion is a commonsense, nontechnical conception]], which requires that officers articulate a reason, beyond a mere hunch, for their belief that an individual has committed a criminal act.” State v. Funderburg, 2008-NMSC-026, ¶ 15 , 144 N.M. 37 , 183 P.3d 922 (second alteration in original) (internal quotation marks and citation omitted).

2012Determining whether reasonable suspicion exists “is a fact-specific inquiry that does not lend itself to bright-line rules.” Id. “[RJeasonable suspicion is a commonsense, nontechnical conception]], which requires that officers articulate a reason, beyond a mere hunch, for their belief that an individual has committed a criminal act.” State v. Funderburg, 2008-NMSC-026, ¶ 15 , 144 N.M. 37 , 183 P.3d 922 (second alteration in original) (internal quotation marks and citation omitted).

12012–2012
Fevig v. Fevig green
nm · 1977
1 sentence

2012Id.

12012–2012
State v. Neal green
nm · 2007
2 sentences

2012A “reasonable suspicion determination requires us to assess the totality of the circumstances and precludes ... [a] divide-and-conquer analysis in which we view each individual factor or circumstance in a vacuum.” State v. Neal, 2007-NMSC-043, ¶ 28 , 142 N.M. 176 , 164 P.3d 57 (alteration and omission in original) (internal quotation marks and citation omitted).

2012A “reasonable suspicion determination requires us to assess the totality of the circumstances and precludes ... [a] divide-and-conquer analysis in which we view each individual factor or circumstance in a vacuum.” State v. Neal, 2007-NMSC-043, ¶ 28 , 142 N.M. 176 , 164 P.3d 57 (alteration and omission in original) (internal quotation marks and citation omitted).

12012–2012
Lozoya v. Sanchez green
nm · 2003
12011–2011
State v. Steinzig green
nmctapp · 1999
12004–2004
cluster 771473 green
ca7 · 2000
12004–2004

Where else courts name it

TX 117 (1994–2026) OR 106 (1991–2026) WA 79 (1992–2026) CA 74 (1995–2026) MI 68 (1999–2026) IL 63 (2002–2025) PA 60 (1993–2026) NY 59 (1995–2026) NJ 57 (1993–2026) CT 38 (1986–2025) NM 35 (1998–2025) TN 29 (1999–2024) NC 29 (2003–2025) LA 28 (1993–2022) ND 27 (2002–2021) VA 25 (2002–2026) AZ 25 (1992–2026) CO 25 (1989–2026) OH 24 (2003–2026) MA 22 (2002–2025) SC 21 (2000–2026) DC 20 (1991–2025) MD 20 (1995–2024) ME 20 (1997–2025) DE 16 (2015–2025) WI 15 (1994–2026) MO 14 (2001–2025) NV 14 (1991–2022) FL 13 (2005–2026) IA 13 (2000–2023) NH 12 (1990–2025) KS 11 (2000–2025) IN 9 (1998–2025) MN 9 (2001–2024) VT 9 (2000–2025) WV 8 (1984–2023) KY 8 (2008–2026) GA 8 (2014–2025) MT 7 (2006–2022) WY 6 (2010–2025) UT 6 (1997–2025) AL 6 (1998–2017) RI 5 (2004–2020) NE 5 (2016–2020) SD 5 (1998–2022) OK 5 (1998–2024) AK 4 (2009–2019) ID 4 (2013–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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