automobile exception (New Mexico) · Go Syfert
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automobile exception in New Mexico

14 New Mexico opinions name it 2 courts 1965–2022 2 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 (9)

CaseFollowedCited
Ohio v. Robinettegreen
scotus · 1996 · cited in 2 New Mexico opinions naming this issue, 1997–2001
2 sentences

2001Moreover, as a second justification for departure, we recognized that the United States Supreme Court's blanket adoption of a bright-line rule, such as the automobile exception, caused tension in the Supreme Court's pronouncements which disavowed bright-line rules in favor of "`emphasizing the fact-specific nature of the reasonableness inquiry.'" Id. ¶ 45 (quoting Ohio v. Robinette, 519 U.S. 33, 34 , 117 S.Ct. 417 , 136 L.Ed.2d 347 (1996)).

2001Moreover, as a second justification for departure, we recognized that the United States Supreme Court's blanket adoption of a bright-line rule, such as the automobile exception, caused tension in the Supreme Court's pronouncements which disavowed bright-line rules in favor of "`emphasizing the fact-specific nature of the reasonableness inquiry.'" Id. ¶ 45 (quoting Ohio v. Robinette, 519 U.S. 33, 34 , 117 S.Ct. 417 , 136 L.Ed.2d 347 (1996)).

12
Cooper v. Californiagreen
scotus · 1967 · cited in 1 New Mexico opinions naming this issue, 2009–2009
1 sentence

2009See, e.g., Cooper v. 7 1 California, 386 U.S. 58, 59 (1967); Preston v. United States, 376 U.S. 364 , 366-67 2 (1964).

11
United States v. Randy Grahamgreen
ca6 · 2001 · cited in 1 New Mexico opinions naming this issue, 2009–2009
1 sentence

2009See 18 id.; South Dakota v. Opperman, 428 U.S. 364, 376 (1976) (concluding that the 19 warrantless inventory search of an impounded vehicle was reasonable); United States 20 v. Graham, 275 F.3d 490, 509 (6th Cir. 2001) (holding that, since Carney, “the 21 necessity of a special exigency has waned”); United States v. Mercado, 307 F.3d 8 1 1226, 1231 (10th Cir. 2002) (“[W]hen probable cause exists, the agents’ time and 2 opportunity to obtain a warrant are irrelevant.”) (internal citation and quotation marks 3 omitted).

11
South Dakota v. Oppermangreen
scotus · 1976 · cited in 1 New Mexico opinions naming this issue, 2009–2009
1 sentence

2009See 18 id.; South Dakota v. Opperman, 428 U.S. 364, 376 (1976) (concluding that the 19 warrantless inventory search of an impounded vehicle was reasonable); United States 20 v. Graham, 275 F.3d 490, 509 (6th Cir. 2001) (holding that, since Carney, “the 21 necessity of a special exigency has waned”); United States v. Mercado, 307 F.3d 8 1 1226, 1231 (10th Cir. 2002) (“[W]hen probable cause exists, the agents’ time and 2 opportunity to obtain a warrant are irrelevant.”) (internal citation and quotation marks 3 omitted).

11
State v. Gomezgreen
nm · 1997 · cited in 1 New Mexico opinions naming this issue, 2009–2009
2 sentences

2009See State v. Gomez, 1997-NMSC-006 , 2 ¶ 19, 122 N.M. 777 , 932 P.2d 1 . 3 1.

2009See State v. Gomez, 1997-NMSC-006 , 2 ¶ 19, 122 N.M. 777 , 932 P.2d 1 . 3 1.

11
State v. Bomboygreen
nm · 2008 · cited in 1 New Mexico opinions naming this issue, 2009–2009
1 sentence

2009See Bomboy, 2008-NMSC-029, ¶ 6 .

11
United States v. Charles N. Matthewsgreen
ca10 · 1980 · cited in 1 New Mexico opinions naming this issue, 1989–1989
2 sentences

1989United States v. Matthews, 615 F.2d 1279, 1287 (10th Cir.1980), sets forth the following regarding the finding of probable cause for a warrantless search under the automobile exception: The probable cause requirement is satisfied when the officers conducting the search have "reasonable or probable cause" to believe that they will find the instrumentality of a crime or evidence pertaining to a crime before they begin their warrantless search.

1989United States v. Matthews, 615 F.2d 1279, 1287 (10th Cir.1980), sets forth the following regarding the finding of probable cause for a warrantless search under the automobile exception: The probable cause requirement is satisfied when the officers conducting the search have “reasonable or probable cause” to believe that they will find the instrumentality of a crime or evidence pertaining to a crime before they begin their warrantless search.

11
Union Central Life Insurance v. Cofergreen
gactapp · 1961 · cited in 1 New Mexico opinions naming this issue, 1965–1965
1 sentence

1965See Union Central Life Insurance Co. v. Cofer, 1961, 103 Ga.App. 355 , 119 S.E.2d 281 , in which the court stated: “Nor does the fact that the speed of the automobile was in violation of law affect the coverage of the policy, in the absence of an exception to that effect. * * * ” (Emphasis added.) In our opinion, the use of the term “accidental means” in the policy here involved was synonymous with “accident.” This leaves only the question of whether or not the trial court should have left to the jury a determination as to whether the death of the decedent was effected by accident.

11
Roberts v. Stategreen
gactapp · 1961 · cited in 1 New Mexico opinions naming this issue, 1965–1965
1 sentence

1965See Union Central Life Insurance Co. v. Cofer, 1961, 103 Ga.App. 355 , 119 S.E.2d 281 , in which the court stated: “Nor does the fact that the speed of the automobile was in violation of law affect the coverage of the policy, in the absence of an exception to that effect. * * * ” (Emphasis added.) In our opinion, the use of the term “accidental means” in the policy here involved was synonymous with “accident.” This leaves only the question of whether or not the trial court should have left to the jury a determination as to whether the death of the decedent was effected by accident.

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 (13)

CaseCitedYears
State v. Cardenas-Alvarez green
nm · 2001
2 sentences

2022In Gomez, our Supreme Court recognized that the automobile exception to the warrant requirement, like the inventory search exception at issue here, “was based, in part, on the notion that a motorist has a lesser expectation of privacy in an automobile.” Cardenas-Alvarez, 2001-NMSC-017, ¶ 15 .

2022In Gomez, our Supreme Court recognized that the automobile exception to the warrant requirement, like the inventory search exception at issue here, “was based, in part, on the notion that a motorist has a lesser expectation of privacy in an automobile.” Cardenas-Alvarez, 2001-NMSC-017, ¶ 15 .

22022–2022
Wyoming v. Houghton green
scotus · 1999
2 sentences

2013The automobile exception is justified in part by the recognition that passengers, as well as drivers, “possess a reduced expectation of privacy with regard to the property that they transport in cars.” Houghton, 526 U.S. at 303 . {45} We do not believe that the principles underlying Ross and Houghton apply in this matter because neither case involves the search of the personal property of a person who is not subject to the search warrant and who has stored his or her property on premises that are open to the public.

2013The automobile exception is justified in part by the recognition that passengers, as well as drivers, “possess a reduced expectation of privacy with regard to the property that they transport in cars.” Houghton, 526 U.S. at 303 . {45} We do not believe that the principles underlying Ross and Houghton apply in this matter because neither case involves the search of the personal property of a person who is not subject to the search warrant and who has stored his or her property on premises that are open to the public.

22013–2013
Preston v. United States green
scotus · 1964
1 sentence

2009See, e.g., Cooper v. 7 1 California, 386 U.S. 58, 59 (1967); Preston v. United States, 376 U.S. 364 , 366-67 2 (1964).

12009–2009
State v. Capps green
nm · 1982
2 sentences

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: "(1)[t]here must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile's mobility and fear that evidence could be destroyed." Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the offi

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: "(1)[t]here must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile's mobility and fear that evidence could be destroyed." Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the offi

11991–1991
Arthur Treacher's Fish & Chips, Inc. v. Horstmyer green
scotus · 1982
2 sentences

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: "(1)[t]here must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile's mobility and fear that evidence could be destroyed." Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the offi

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: “(1) [tjhere must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile’s mobility and fear that evidence could be destroyed.” Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the off

11991–1991
Wilson v. Wilson green
scotus · 1982
2 sentences

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: "(1)[t]here must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile's mobility and fear that evidence could be destroyed." Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the offi

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: “(1) [tjhere must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile’s mobility and fear that evidence could be destroyed.” Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the off

11991–1991
Wilder v. Gilman Paper Co. green
scotus · 1982
2 sentences

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: "(1)[t]here must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile's mobility and fear that evidence could be destroyed." Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the offi

1991In State v. Capps, 97 N.M. 453, 455 , 641 P.2d 484, 486 , cert. denied, 458 U.S. 1107 , 102 S.Ct. 3486 , 73 L.Ed.2d 1368 (1982), our supreme court set forth two requirements of the automobile exception: “(1) [tjhere must be probable cause that the automobile contains evidence of a crime, and (2) there must be an exigency to search the automobile at that moment, because of the automobile’s mobility and fear that evidence could be destroyed.” Included in the second requirement is the premise that the automobile, as opposed to a particular container within the automobile, is the target of the off

11991–1991
United States v. Joseph Charles Milhollan, A/K/A Alec Leroy Foltz green
ca3 · 1979
2 sentences

1982The majority, however, citing Milhollan, supra, persist in arguing that, since the automobile was mobile and the discovery of the bags was unexpected, there were exigent circumstances to justify application of the automobile exception to the warrant requirement.

1982The majority, however, citing Milhollan, supra, persist in arguing that, since the automobile was mobile and the discovery of the bags was unexpected, there were exigent circumstances to justify application of the automobile exception to the warrant requirement.

11982–1982
State v. Ellis green
nmctapp · 1975
2 sentences

1981Thus, in State v. Ellis, 88 N.M. 90 , 537 P.2d 698 (Ct.App.1975), we said: The constitutional prohibition against an unreasonable search is a personal right enforceable by one whose own protection was infringed by the search.

1981Thus, in State v. Ellis, 88 N.M. 90 , 537 P.2d 698 (Ct.App.1975), we said: The constitutional prohibition against an unreasonable search is a personal right enforceable by one whose own protection was infringed by the search.

11981–1981
State v. Barton green
nmctapp · 1978
2 sentences

1978State v. Luna, 91 N.M. 560 , 577 P.2d 458 (Ct.App.1978); State v. Barton, 92 N.M. 118 , 584 P.2d 165 (Ct.App.1978).

1978State v. Luna, 91 N.M. 560 , 577 P.2d 458 (Ct.App.1978); State v. Barton, 92 N.M. 118 , 584 P.2d 165 (Ct.App.1978).

11978–1978
State v. Luna green
nmctapp · 1978
2 sentences

1978State v. Luna, 91 N.M. 560 , 577 P.2d 458 (Ct.App.1978); State v. Barton, 92 N.M. 118 , 584 P.2d 165 (Ct.App.1978).

1978State v. Luna, 91 N.M. 560 , 577 P.2d 458 (Ct.App.1978); State v. Barton, 92 N.M. 118 , 584 P.2d 165 (Ct.App.1978).

11978–1978
United States v. Chadwick red
scotus · 1977
2 sentences

1978United States v. Chadwick, 433 U.S. 1 , 97 S.Ct. 2476 , 53 L.Ed.2d 538 (1977); Chambers v. Maroney, 399 U.S. 42 , 90 S.Ct. 1975 , 26 L.Ed.2d 419 (1970).

1978United States v. Chadwick, 433 U.S. 1 , 97 S.Ct. 2476 , 53 L.Ed.2d 538 (1977); Chambers v. Maroney, 399 U.S. 42 , 90 S.Ct. 1975 , 26 L.Ed.2d 419 (1970).

11978–1978
Chambers v. Maroney green
scotus · 1970
2 sentences

1978United States v. Chadwick, 433 U.S. 1 , 97 S.Ct. 2476 , 53 L.Ed.2d 538 (1977); Chambers v. Maroney, 399 U.S. 42 , 90 S.Ct. 1975 , 26 L.Ed.2d 419 (1970).

1978United States v. Chadwick, 433 U.S. 1 , 97 S.Ct. 2476 , 53 L.Ed.2d 538 (1977); Chambers v. Maroney, 399 U.S. 42 , 90 S.Ct. 1975 , 26 L.Ed.2d 419 (1970).

11978–1978

Statutes the citing opinions construe

NM § N.M. Stat. § 30-31-23 (5)

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

OH 258 (1929–2026) NY 250 (1920–2026) TX 239 (1936–2026) NJ 137 (1966–2026) PA 130 (1932–2026) CA 125 (1919–2026) OR 100 (1930–2026) ID 82 (1976–2026) LA 81 (1960–2025) IL 80 (1974–2026) MA 71 (1934–2026) IN 66 (1929–2025) MI 66 (1940–2026) IA 59 (1979–2026) VA 55 (1939–2025) MD 54 (1968–2026) GA 49 (1927–2022) CO 38 (1971–2026) FL 36 (1971–2025) MO 33 (1914–2025) KS 33 (1982–2024) TN 33 (1926–2026) WI 33 (1925–2025) ND 31 (1981–2026) MN 31 (1979–2025) SC 28 (1986–2026) NE 26 (1944–2026) CT 26 (1968–2025) UT 26 (1980–2022) NC 24 (1938–2026) MS 24 (1968–2025) AL 24 (1957–2010) KY 23 (1969–2026) AZ 17 (1979–2022) DE 15 (1934–2024) DC 15 (1979–2026) WA 14 (1934–2016) NM 14 (1965–2022) ME 13 (1979–2021) WY 11 (1979–2019) AR 11 (1931–2015) OK 11 (1923–2024) WV 10 (1978–2015) NV 9 (1997–2021) RI 8 (1989–2023) VT 8 (1933–2019) HI 7 (1978–2020) MT 6 (1978–2025) NH 5 (1990–2018) SD 5 (2000–2016) VI 4 (2012–2026) AK 3 (1978–1983)

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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