community caretaker exception (New Mexico) · Go Syfert
← New Mexico issues

community caretaker exception in New Mexico

28 New Mexico opinions name it 2 courts 2001–2025 5 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. Ryongreen
nm · 2005 · cited in 14 New Mexico opinions naming this issue, 2007–2023
2 sentences

2023In Ryon, our Supreme Court clarified that “[w]hen determining whether a warrantless search or seizure is reasonable on the basis of the community caretaker exception, we must measure the public need and interest furthered by the police conduct against the degree of and nature of the intrusion upon the privacy of the citizen.” 2005-NMSC-005, ¶ 24 (internal quotation marks and citation omitted).

2017In Ryon, our Supreme Court clarified the scope 3 of the community caretaker exception in New Mexico. 2005-NMSC-005, ¶ 1 .

714
State v. Nemethgreen
nmctapp · 2001 · cited in 4 New Mexico opinions naming this issue, 2004–2005
2 sentences

2005Deputies Sanchez, Pepin, and Neel testified at the suppression hearing, and an offer of proof was made on behalf of Defendant and his mother to establish the relevant time frames. {7} After the hearing, the district court applied the community caretaker exception articulated in Nemeth and found the search was unlawful. 2001-NMCA-029, ¶¶ 37-38 , 130 N.M. 261 , 23 P.3d 936 .

2005Deputies Sanchez, Pepin, and Neel testified at the suppression hearing, and an offer of proof was made on behalf of Defendant and his mother to establish the relevant time frames. {7} After the hearing, the district court applied the community caretaker exception articulated in Nemeth and found the search was unlawful. 2001-NMCA-029, ¶¶ 37-38 , 130 N.M. 261 , 23 P.3d 936 .

34
State v. Reynoldsgreen
nmctapp · 1994 · cited in 3 New Mexico opinions naming this issue, 2001–2017
2 sentences

2017Our decision relied on State v. Reynolds , 1993-NMCA-162 , 117 N.M. 23 , 868 P.2d 668 , rev'd on other grounds by 1995-NMSC-008 , 119 N.M. 383 , 890 P.2d 1315 . {37} Both cases, Reynolds and Apodaca , fall into a different line of cases-those applying the public servant doctrine of the community caretaker exception.

2017Our decision relied on State v. Reynolds , 1993-NMCA-162 , 117 N.M. 23 , 868 P.2d 668 , rev'd on other grounds by 1995-NMSC-008 , 119 N.M. 383 , 890 P.2d 1315 . {37} Both cases, Reynolds and Apodaca , fall into a different line of cases-those applying the public servant doctrine of the community caretaker exception.

23
State v. Gutierrezgreen
nmctapp · 2008 · cited in 2 New Mexico opinions naming this issue, 2009–2009
2 sentences

2009See Gutierrez, 2008-NMCA-015, ¶ 14 , 143 N.M. 522 , 177 P.3d 1096 (stating that "[d]espite the officers' initial intent to merely ask [the d]efendant a few questions, the encounter quickly escalated into an investigatory detention").

2009See Gutieirez, 2008-NMCA-015, ¶ 14 , 143 N.M. 522 , 177 P.3d 1096 (stating that “[djespite the officers’ initial intent to merely ask [the defendant a few questions, the encounter quickly escalated into an investigatory detention”).

22
State v. Gutierrezgreen
nmctapp · 2007 · cited in 2 New Mexico opinions naming this issue, 2009–2009
2 sentences

2009See Gutieirez, 2008-NMCA-015, ¶ 14 , 143 N.M. 522 , 177 P.3d 1096 (stating that “[djespite the officers’ initial intent to merely ask [the defendant a few questions, the encounter quickly escalated into an investigatory detention”).

2009See Gutieirez, 2008-NMCA-015, ¶ 14 , 143 N.M. 522 , 177 P.3d 1096 (stating that “[djespite the officers’ initial intent to merely ask [the defendant a few questions, the encounter quickly escalated into an investigatory detention”).

22
State v. Corneaugreen
nmctapp · 1989 · cited in 2 New Mexico opinions naming this issue, 2007–2007
2 sentences

2007A warrantless search is presumptively unreasonable, “unless it falls within an exception to the warrant requirement.” State v. Corneau, 109 N.M. 81, 89 , 781 P.2d 1159, 1167 (Ct.App.1989). {15} The State asserts that the officers’ first entry into Defendants’ home was a permissible protective sweep, or fell under the community caretaker exception to the warrant requirement.

2007A warrantless search is presumptively unreasonable, “unless it falls within an exception to the warrant requirement.” State v. Corneau, 109 N.M. 81, 89 , 781 P.2d 1159, 1167 (Ct.App.1989). {15} The State asserts that the officers’ first entry into Defendants’ home was a permissible protective sweep, or fell under the community caretaker exception to the warrant requirement.

22
State v. Waltersgreen
nmctapp · 1996 · cited in 3 New Mexico opinions naming this issue, 2005–2025
2 sentences

2025Having considered the brief in chief, concluding the briefing submitted to the Court provides no possibility for reversal, and determining that this case is appropriate for resolution on Track 1 as defined in that order, we affirm for the following reasons. {2} Defendant entered into a conditional plea, reserving his right to appeal from the district court’s order denying his motion to suppress. [BIC 1] Specifically, he argues that the district court erred in denying his suppression motion because the officer who stopped him did not have reasonable suspicion and was not acting pursuant to the

2025Having considered the brief in chief, concluding the briefing submitted to the Court provides no possibility for reversal, and determining that this case is appropriate for resolution on Track 1 as defined in that order, we affirm for the following reasons. {2} Defendant entered into a conditional plea, reserving his right to appeal from the district court’s order denying his motion to suppress. [BIC 1] Specifically, he argues that the district court erred in denying his suppression motion because the officer who stopped him did not have reasonable suspicion and was not acting pursuant to the

13
Apodaca v. State, Tax and Revenue Dept.green
nmctapp · 1994 · cited in 3 New Mexico opinions naming this issue, 2005–2017
2 sentences

2017See Apodaca , 1994-NMCA-120 , ¶ 2, 884 P.2d 515 (describing a driver operating a motorcycle on highway erratically); Reynolds , 1993-NMCA-162 , ¶ 2, 868 P.2d 668 (describing a driver operating a vehicle on highway with an open tailgate and three passengers with feet dangling).

2005Id. at 626, 884 P.2d at 517 .

13
State v. Sheehangreen
nmctapp · 2015 · cited in 2 New Mexico opinions naming this issue, 2015–2023
2 sentences

2023See Sheehan, 2015-NMCA-021, ¶ 9 (“Therefore, when police act as community caretakers, the existence of reasonable suspicion or grounds for probable cause are not appropriate inquiries.” (text only) (citation omitted)). {22} We conclude that Defendant has not presented a prima facie case of ineffective assistance of counsel.

2015The third doctrine, which we will refer to as the public servant doctrine, 16 applies to warrantless searches and seizures of automobiles and is at issue in this case. 17 Ryon, 2005-NMSC-005, ¶ 26 ; Sheehan, 2015-NMCA-021, ¶ 12 . 18 {10} “When determining whether a warrantless search or seizure is reasonable on 19 the basis of the community caretaker exception, [an appellate court] must measure the 5 1 public need and interest furthered by the police conduct against the degree of and 2 nature of the intrusion upon the privacy of the citizen.” Ryon, 2005-NMSC-005 , ¶ 24 3 (internal quotation ma

12
South Dakota v. Oppermangreen
scotus · 1976 · cited in 2 New Mexico opinions naming this issue, 2005–2023
2 sentences

2005When determining whether a warrantless search or seizure is reasonable on the basis of the community caretaker exception, we must measure “ ‘the public need and interest furthered by the police conduct against the degree of and nature of the intrusion upon the privacy of the citizen.’ ” Reynolds, 119 N.M. at 388 , 890 P.2d at 1320 (quoting Ellenbecker, 464 N.W.2d at 429 ). {25} In balancing these interests, three distinct doctrines under the community caretaker exception have emerged: “1) the emergency aid doctrine, established in Mincey; 2) the automobile impoundment and inventory doctrine, f

2005When determining whether a warrantless search or seizure is reasonable on the basis of the community caretaker exception, we must measure “ ‘the public need and interest furthered by the police conduct against the degree of and nature of the intrusion upon the privacy of the citizen.’ ” Reynolds, 119 N.M. at 388 , 890 P.2d at 1320 (quoting Ellenbecker, 464 N.W.2d at 429 ). {25} In balancing these interests, three distinct doctrines under the community caretaker exception have emerged: “1) the emergency aid doctrine, established in Mincey; 2) the automobile impoundment and inventory doctrine, f

12
Brigham City v. Stuartgreen
scotus · 2006 · cited in 2 New Mexico opinions naming this issue, 2019–2019
2 sentences

2019Mindful that the need to render emergency assistance may arise in the course of a criminal investigation, we clarified that "[a]lthough the police need not be totally unconcerned with the apprehension of suspects or the collection of evidence, the motivation for the intrusion must be a strong sense of emergency[.]" Id. ¶ 39. {22} The year after the Ryon decision, the United States Supreme Court ruled in Brigham City that an officer's subjective motivation was irrelevant in assessing the reasonableness of an entry under the emergency assistance doctrine. 547 U.S. at 404 , 126 S.Ct. 1943 ("An ac

2019Mindful that the need to render emergency assistance may arise in the course of a criminal investigation, we clarified that "[a]lthough the police need not be totally unconcerned with the apprehension of suspects or the collection of evidence, the motivation for the intrusion must be a strong sense of emergency[.]" Id. ¶ 39. {22} The year after the Ryon decision, the United States Supreme Court ruled in Brigham City that an officer's subjective motivation was irrelevant in assessing the reasonableness of an entry under the emergency assistance doctrine. 547 U.S. at 404 , 126 S.Ct. 1943 ("An ac

12
People v. Davisgreen
mich · 1993 · cited in 2 New Mexico opinions naming this issue, 2001–2005
2 sentences

2005The court noted that under Nemeth, the exception “can be invoked only ‘when the police are not engaged in crime-solving activities.’ ” See id. ¶ 38 (quoting People v. Davis, 442 Mich. 1 , 497 N.W.2d 910, 920 (1993)).

2005The court noted that under Nemeth, the exception “can be invoked only ‘when the police are not engaged in crime-solving activities.’ ” See id. ¶ 38 (quoting People v. Davis, 442 Mich. 1 , 497 N.W.2d 910, 920 (1993)).

12
State v. Garciagreen
nm · 2009 · cited in 1 New Mexico opinions naming this issue, 2023–2023
2 sentences

2023See State v. Garcia, 2009-NMSC-046, ¶ 27 , 147 N.M. 134 , 217 P.3d 1032 (stating that “[u]nder our interstitial approach to interpreting the New Mexico Constitution, we may diverge from federal precedent where the federal analysis is flawed, where there are structural differences between the state and federal governments, or because of distinctive New Mexico characteristics”). {7} Considering the totality of the circumstances, the officer stopped his car on the side of the road to check on Defendant based on a “specific, articulable safety concern in [his] capacity as [a] community caretaker[]

2023See State v. Garcia, 2009-NMSC-046, ¶ 27 , 147 N.M. 134 , 217 P.3d 1032 (stating that “[u]nder our interstitial approach to interpreting the New Mexico Constitution, we may diverge from federal precedent where the federal analysis is flawed, where there are structural differences between the state and federal governments, or because of distinctive New Mexico characteristics”). {7} Considering the totality of the circumstances, the officer stopped his car on the side of the road to check on Defendant based on a “specific, articulable safety concern in [his] capacity as [a] community caretaker[]

11
State v. Ochoagreen
nm · 2004 · cited in 1 New Mexico opinions naming this issue, 2023–2023
2 sentences

2023See State v. Ochoa, 2004-NMSC-023, ¶ 9 , 135 N.M. 781 , 93 P.3d 1286 (stating “[p]robable cause exists when the facts and circumstances warrant a belief that the accused had committed an offense, or is committing an offense”). {14} We conclude that the community caretaker exception applied up until the point that the officer became aware of the inconsistencies in Defendant’s statements relating to the vehicles.

2023See State v. Ochoa, 2004-NMSC-023, ¶ 9 , 135 N.M. 781 , 93 P.3d 1286 (stating “[p]robable cause exists when the facts and circumstances warrant a belief that the accused had committed an offense, or is committing an offense”). {14} We conclude that the community caretaker exception applied up until the point that the officer became aware of the inconsistencies in Defendant’s statements relating to the vehicles.

11
State v. Palmergreen
nmctapp · 1998 · cited in 1 New Mexico opinions naming this issue, 2023–2023
2 sentences

2023See State v. Palmer, 1998-NMCA-052, ¶ 12 , 125 N.M. 86 , 957 P.2d 71 . {6} It is well established that an officer acting as a community caretaker is a recognized exception to the Fourth Amendment.

2023See State v. Palmer, 1998-NMCA-052, ¶ 12 , 125 N.M. 86 , 957 P.2d 71 . {6} It is well established that an officer acting as a community caretaker is a recognized exception to the Fourth Amendment.

11
State v. Mosleygreen
nmctapp · 2014 · cited in 1 New Mexico opinions naming this issue, 2023–2023
1 sentence

2023Defendant fails to establish that the record reflects that Officer Villarreal acted outside of the scope of the community caretaker exception, and as such cannot show the “facts support the motion to suppress and that a reasonably competent attorney could not have decided that such a motion was unwarranted.” See Mosley, 2014-NMCA-094, ¶ 20 (internal quotation marks and citation omitted).

11
State v. Trudellegreen
nmctapp · 2007 · cited in 1 New Mexico opinions naming this issue, 2017–2017
1 sentence

2017According to Ryon, “[s]ince the privacy expectation is strongest in the home[,] only a genuine emergency will justify entering and searching a home without a warrant and without consent[.]” Id.; see Trudelle, 2007-NMCA-066, ¶ 35 (“Our Supreme Court has stated that, when police conduct a warrantless search of a home in their community caretaking capacity, the search must be analyzed under the emergency assistance branch of the community caretaker exception.”).

11
State v. Boswellgreen
nm · 1991 · cited in 1 New Mexico opinions naming this issue, 2017–2017
11
State v. Hubblegreen
nm · 2009 · cited in 1 New Mexico opinions naming this issue, 2017–2017
2 sentences

2017See State v. Hubble, 3 2009-NMSC-014, ¶ 23 , 146 N.M. 70 , 206 P.3d 579 ; Ryon, 2005-NMSC-005, ¶ 30 . 4 {9} Defendant claims that the facts in this case are similar to those in State v. 5 Frazier, 1975-NMCA-074 , 88 N.M. 103 , 537 P.2d 711 , because the defendant in that 6 case was not suspected of committing any crime.

2017See State v. Hubble, 3 2009-NMSC-014, ¶ 23 , 146 N.M. 70 , 206 P.3d 579 ; Ryon, 2005-NMSC-005, ¶ 30 . 4 {9} Defendant claims that the facts in this case are similar to those in State v. 5 Frazier, 1975-NMCA-074 , 88 N.M. 103 , 537 P.2d 711 , because the defendant in that 6 case was not suspected of committing any crime.

11
Campos v. Stategreen
nm · 1994 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
McDonald v. United Statesgreen
scotus · 1948 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
State v. Wixomgreen
idaho · 1997 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
Laney v. Stategreen
texcrimapp · 2003 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
State v. Lopezgreen
nmctapp · 1989 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
State v. Mountfordgreen
vt · 2000 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
Thompson v. Louisianagreen
scotus · 1985 · cited in 1 New Mexico opinions naming this issue, 2005–2005
11
Payton v. New Yorkgreen
scotus · 1980 · cited in 1 New Mexico opinions naming this issue, 2004–2004
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 (25)

CaseCitedYears
Cady v. Dombrowski green
scotus · 1973
2 sentences

2007Accordingly, we exercise our discretion to consider this question in the present case. {84} The United States Supreme Court first recognized the community caretaker exception in Cady v. Dombrowski, 413 U.S. 433 , 93 S.Ct. 2523 , 37 L.Ed.2d 706 (1973).

2007Accordingly, we exercise our discretion to consider this question in the present case. {84} The United States Supreme Court first recognized the community caretaker exception in Cady v. Dombrowski, 413 U.S. 433 , 93 S.Ct. 2523 , 37 L.Ed.2d 706 (1973).

42001–2007
State v. Reynolds green
nm · 1995
2 sentences

2017Our decision relied on State v. Reynolds , 1993-NMCA-162 , 117 N.M. 23 , 868 P.2d 668 , rev'd on other grounds by 1995-NMSC-008 , 119 N.M. 383 , 890 P.2d 1315 . {37} Both cases, Reynolds and Apodaca , fall into a different line of cases-those applying the public servant doctrine of the community caretaker exception.

2017Our decision relied on State v. Reynolds , 1993-NMCA-162 , 117 N.M. 23 , 868 P.2d 668 , rev'd on other grounds by 1995-NMSC-008 , 119 N.M. 383 , 890 P.2d 1315 . {37} Both cases, Reynolds and Apodaca , fall into a different line of cases-those applying the public servant doctrine of the community caretaker exception.

32001–2017
State v. Jason L. green
nm · 2000
2 sentences

2005We agree with both observations. {20} In Jason L., we cited State v. Walters, 1997-NMCA-013 , 123 N.M. 88 , 934 P.2d 282 , for the basic premise that, “community earetaking encounters are consensual, beyond the scope of the Fourth Amendment,” although we did not decide that case under the community caretaker exception. 2000-NMSC-018 , ¶¶ 14, 22, 129 N.M. 119 , 2 P.3d 856 .

2005We agree with both observations. {20} In Jason L., we cited State v. Walters, 1997-NMCA-013 , 123 N.M. 88 , 934 P.2d 282 , for the basic premise that, “community earetaking encounters are consensual, beyond the scope of the Fourth Amendment,” although we did not decide that case under the community caretaker exception. 2000-NMSC-018 , ¶¶ 14, 22, 129 N.M. 119 , 2 P.3d 856 .

22001–2005
State v. Rubio green
nmctapp · 2006
2 sentences

2023We have stated that this check may include a wants and warrants check.” State v. Rubio, 2006-NMCA- 067, ¶ 14, 139 N.M. 612 , 136 P.3d 1022 . {21} Because the facts in this record regarding Officer Villarreal’s encounter with Defendant could support a conclusion by a reasonable attorney that Officer Villarreal acted within the scope of the community caretaker exception, we decline to address Defendant’s argument that the seizure was not supported by reasonable suspicion or Defendant’s argument that the evidence was not sufficiently attenuated from the seizure to be admissible.

2023We have stated that this check may include a wants and warrants check.” State v. Rubio, 2006-NMCA- 067, ¶ 14, 139 N.M. 612 , 136 P.3d 1022 . {21} Because the facts in this record regarding Officer Villarreal’s encounter with Defendant could support a conclusion by a reasonable attorney that Officer Villarreal acted within the scope of the community caretaker exception, we decline to address Defendant’s argument that the seizure was not supported by reasonable suspicion or Defendant’s argument that the evidence was not sufficiently attenuated from the seizure to be admissible.

12023–2023
Schuster v. New Mexico Dep't. of Taxation & Revenue green
nm · 2012
2 sentences

2023Cf. State v. Ochoa, 2009-NMCA-002, ¶ 11 , 146 N.M. 32 , 206 P.3d 143 (holding that the defendant’s pretextual argument had been properly preserved because he developed relevant facts in the district court). 2012-NMSC-025, ¶ 26 , 283 P.3d 288 (“An officer who is acting as a community caretaker does not violate the Fourth Amendment.”).

2023Accordingly, “[t]he test we employ is one of objective reasonableness based on the totality of the circumstances.” Schuster, 2012-NMSC-025, ¶ 26 .

12023–2023
State v. Ochoa green
nmctapp · 2008
2 sentences

2023Cf. State v. Ochoa, 2009-NMCA-002, ¶ 11 , 146 N.M. 32 , 206 P.3d 143 (holding that the defendant’s pretextual argument had been properly preserved because he developed relevant facts in the district court). 2012-NMSC-025, ¶ 26 , 283 P.3d 288 (“An officer who is acting as a community caretaker does not violate the Fourth Amendment.”).

2023Cf. State v. Ochoa, 2009-NMCA-002, ¶ 11 , 146 N.M. 32 , 206 P.3d 143 (holding that the defendant’s pretextual argument had been properly preserved because he developed relevant facts in the district court). 2012-NMSC-025, ¶ 26 , 283 P.3d 288 (“An officer who is acting as a community caretaker does not violate the Fourth Amendment.”).

12023–2023
State v. Leyba green
nmctapp · 1997
2 sentences

2023Defendant and [his wife] were not in peril and did not need assistance.” Ultimately, the district court found that the stop was expanded into an investigatory stop and the “expansion of the stop was proper and was supported by reasonable suspicion . . . that Defendant was breaking or had broken the law.” {4} On appeal from a district court’s ruling on a motion to suppress, “we afford de novo review of the [district] court’s legal conclusions.” State v. Leyba, 1997-NMCA-023, ¶ 8 , 123 N.M. 159 , 935 P.2d 1171 .

2023Defendant and [his wife] were not in peril and did not need assistance.” Ultimately, the district court found that the stop was expanded into an investigatory stop and the “expansion of the stop was proper and was supported by reasonable suspicion . . . that Defendant was breaking or had broken the law.” {4} On appeal from a district court’s ruling on a motion to suppress, “we afford de novo review of the [district] court’s legal conclusions.” State v. Leyba, 1997-NMCA-023, ¶ 8 , 123 N.M. 159 , 935 P.2d 1171 .

12023–2023
State v. Martinez green
nm · 2018
1 sentence

2022This Court, however, “must indulge in all reasonable inferences in support of the district court’s decision and disregard all inferences or evidence to the contrary.” State v. Martinez, 2018-NMSC- 007, ¶ 15, 410 P.3d 186 (text only).

12022–2022
State v. Shaw green
nmctapp · 1993
2 sentences

2017Defendant also argued that none of the exceptions to the Fourth Amendment's warrant requirement applied: Sergeant Foreman did not arrest Defendant, so the search cannot be justified as a search incident to arrest; there existed no exigencies requiring Sergeant Foreman to search the vehicle in order to preserve a life or prevent serious damage to property; Defendant did not consent to the search; and nothing in plain view in the vehicle gave rise to Sergeant Foreman's perceived need to search the vehicle. {6} In response to the motion, the State argued that the warrantless search of Defendant's

2017Defendant also argued that none of the exceptions to the Fourth Amendment's warrant requirement applied: Sergeant Foreman did not arrest Defendant, so the search cannot be justified as a search incident to arrest; there existed no exigencies requiring Sergeant Foreman to search the vehicle in order to preserve a life or prevent serious damage to property; Defendant did not consent to the search; and nothing in plain view in the vehicle gave rise to Sergeant Foreman's perceived need to search the vehicle. {6} In response to the motion, the State argued that the warrantless search of Defendant's

12017–2017
State v. Frazier green
nmctapp · 1975
1 sentence

2017See State v. Hubble, 3 2009-NMSC-014, ¶ 23 , 146 N.M. 70 , 206 P.3d 579 ; Ryon, 2005-NMSC-005, ¶ 30 . 4 {9} Defendant claims that the facts in this case are similar to those in State v. 5 Frazier, 1975-NMCA-074 , 88 N.M. 103 , 537 P.2d 711 , because the defendant in that 6 case was not suspected of committing any crime.

12017–2017
State v. Kenard green
nmctapp · 1975
1 sentence

2017See State v. Hubble, 3 2009-NMSC-014, ¶ 23 , 146 N.M. 70 , 206 P.3d 579 ; Ryon, 2005-NMSC-005, ¶ 30 . 4 {9} Defendant claims that the facts in this case are similar to those in State v. 5 Frazier, 1975-NMCA-074 , 88 N.M. 103 , 537 P.2d 711 , because the defendant in that 6 case was not suspected of committing any crime.

12017–2017
State v. Williams green
nm · 1982
2 sentences

2017See State v. Boswell , 1991-NMSC-004 , ¶ 2, 111 N.M. 240 , 804 P.2d 1059 (describing arrest prior to the search of the arrestee's wallet); State v. Williams , 1982-NMSC-041 , ¶ 2, 97 N.M. 634 , 642 P.2d 1093 (describing arrest prior to the search of the arrestee's vehicle); Ruffino , 1980-NMSC-072 , ¶ 2, 612 P.2d 1311 (describing arrest prior to the search of the arrestee's vehicle); Shaw , 1993-NMCA-016 , ¶¶ 2, 3, 848 P.2d 1101 (describing the search of a wallet and a cigarette pack during the arrestee's booking into the detention center). {15} We evaluate the constitutionality of the search

2017See State v. Boswell , 1991-NMSC-004 , ¶ 2, 111 N.M. 240 , 804 P.2d 1059 (describing arrest prior to the search of the arrestee's wallet); State v. Williams , 1982-NMSC-041 , ¶ 2, 97 N.M. 634 , 642 P.2d 1093 (describing arrest prior to the search of the arrestee's vehicle); Ruffino , 1980-NMSC-072 , ¶ 2, 612 P.2d 1311 (describing arrest prior to the search of the arrestee's vehicle); Shaw , 1993-NMCA-016 , ¶¶ 2, 3, 848 P.2d 1101 (describing the search of a wallet and a cigarette pack during the arrestee's booking into the detention center). {15} We evaluate the constitutionality of the search

12017–2017
State v. Ruffino green
nm · 1980
12017–2017
State v. Morales green
nmctapp · 2004
12015–2015
People v. Ray green
cal · 1999
12005–2005
Mincey v. Arizona green
scotus · 1978
12005–2005
United States v. Hector Morales Cervantes, AKA Benito C. Carillo green
ca9 · 2000
12005–2005
State v. Gomez green
nm · 1997
12005–2005
State v. Ellenbecker green
wisctapp · 1990
12005–2005
Vernonia School District 47J v. Acton green
scotus · 1995
12004–2004
Illinois v. McArthur green
scotus · 2001
12004–2004
In Re Josue T. green
nmctapp · 1999
12004–2004
New Jersey v. T. L. O. green
scotus · 1985
12004–2004
Griffin v. Wisconsin green
scotus · 1987
12004–2004
State v. Carlson green
iowa · 1996
12001–2001

Statutes the citing opinions construe

NM § N.M. Stat. § 30-31-25.1 (6) NM § N.M. Stat. § 30-31-23 (5) NM § N.M. Stat. § 30-31-20 (4) NM § N.M. Stat. § 30-22-24 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

WI 47 (1989–2026) VA 43 (1995–2025) NM 28 (2001–2025) MT 27 (2002–2024) NJ 16 (2003–2026) SD 8 (2009–2022) CA 7 (1999–2020) IL 7 (2005–2022) MI 7 (1993–2026) PA 5 (2017–2021) WA 5 (2000–2018) WV 5 (2010–2019) FL 5 (2009–2016) IA 5 (2015–2023) ND 5 (2002–2023) AZ 4 (2007–2018) DE 4 (2008–2021) NE 4 (2015–2018) WY 4 (2008–2020) TN 3 (2013–2016) DC 3 (2002–2015) NC 3 (2014–2017) KY 2 (2022–2024) UT 2 (1997–2000)

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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