probable cause requirement (New Mexico) · Go Syfert
← New Mexico issues

probable cause requirement in New Mexico

51 New Mexico opinions name it 2 courts 1974–2026 11 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 (39)

CaseFollowedCited
Michigan v. Summersgreen
scotus · 1981 · cited in 2 New Mexico opinions naming this issue, 2000–2022
2 sentences

2022The parties instead dispute the applicability of an exception to the probable cause requirement—the exception recognized by the United States Supreme Court in Michigan v. Summers, 452 U.S. 692 (1981), and later extended by this Court in Graves, for detentions incident to premises searches.

2022“In Summers, the United States Supreme Court established another limited exception to the probable cause requirement and ruled that a resident of the premises being searched [pursuant to a warrant] could be detained for the duration of the search.” Graves, 1994-NMCA-151 , ¶ 10; see Summers, 452 U.S. at 705 .

22
State v. Tollardogreen
nm · 2012 · cited in 2 New Mexico opinions naming this issue, 2014–2021
2 sentences

2021See id. ¶¶ 7, 16. of a controlled substance is sufficient evidence to sustain a conviction for possession of a controlled substance), overruled on other grounds by State v. Tollardo, 2012-NMSC- 008, ¶ 37 n.6, 275 P.3d 110 .

2014In her memorandum in opposition Defendant 9 contends that the foregoing considerations should not be deemed sufficient to give rise 10 to probable cause to arrest, in light of her compliance with many of the officer’s 11 instructions as well as the existence of alternative explanations for certain aspects of 12 the behavioral evidence. [MIO 10-12] However, “[a]n appellate court does not 13 evaluate the evidence to determine whether some hypothesis could be designed which 14 is consistent with a finding of innocence.” State v. Sutphin, 1988-NMSC-031 , ¶ 21, 15 107 N.M. 126 , 753 P.2d 1314 ; see

22
McCray v. Illinoisgreen
scotus · 1967 · cited in 2 New Mexico opinions naming this issue, 1974–1974
2 sentences

1974Whiteley v. Warden, supra; see McCray v. Illinois, 386 U.S. 300 , 87 S.Ct. 1056 , 18 L.

1974Whiteley v. Warden, supra; see McCray v. Illinois, 386 U.S. 300 , 87 S.Ct. 1056 , 18 L.

22
State v. Granillo-Maciasgreen
nmctapp · 2007 · cited in 4 New Mexico opinions naming this issue, 2012–2023
2 sentences

2023Insofar as Defendant was arrested for DWI, the “probable cause inquiry is whether it was objectively reasonable for the officer to believe that Defendant had been driving while he was to the slightest degree impaired, that is unable to exercise the clear judgment and steady hand necessary to handle a vehicle in a safe manner.” Id. (internal quotation marks and citation omitted). {6} In this case the officer initiated the traffic stop as a consequence of Defendant’s near-collision with his vehicle, and the ensuing arrest was based on the officer’s observation of Defendant’s bloodshot watery eye

2014Such 3 1 observations are sufficient to satisfy the probable cause requirement. [DS 3-6] See, 2 e.g., Schuster v. State Dep’t of Taxation & Revenue, 2012-NMSC-025, ¶¶ 30-31 , 283 3 P.3d 288 (observing that probable cause to arrest for DWI existed based on the 4 defendant’s bloodshot watery eyes, odor of alcohol, admission to drinking, and poor 5 performance on field sobriety tests); State v. Granillo-Macias, 2008-NMCA-021 , ¶ 6 12, 143 N.M. 455 , 176 P.3d 1187 (holding that an officer had probable cause to arrest 7 for DWI where the defendant smelled of alcohol, was unsteady on his feet, and d

14
State v. Cappsgreen
nm · 1982 · cited in 3 New Mexico opinions naming this issue, 2017–2025
2 sentences

2025See NMSA 1978, § 26-2C-25(A)(1) (2021) (making it 16 “lawful for a person who is twenty-one years of age or older” to “possess[], us[e], 17 be[] under the influence of, display[], purchas[e], obtain[] or transport[] not more 18 cannabis than authorized by the Cannabis Regulation Act or the medical cannabis 19 program”). 1 {2} The narrow question presented here, as certified by the Court of Appeals, is 2 whether this Court’s criminalization-era caselaw holding that “[t]he smell of 3 marijuana alone can satisfy the probable cause requirement for a warrantless search 4 [of a vehicle],” State v. C

2025See NMSA 1978, § 26-2C-25(A)(1) (2021) (making it 16 “lawful for a person who is twenty-one years of age or older” to “possess[], us[e], 17 be[] under the influence of, display[], purchas[e], obtain[] or transport[] not more 18 cannabis than authorized by the Cannabis Regulation Act or the medical cannabis 19 program”). 1 {2} The narrow question presented here, as certified by the Court of Appeals, is 2 whether this Court’s criminalization-era caselaw holding that “[t]he smell of 3 marijuana alone can satisfy the probable cause requirement for a warrantless search 4 [of a vehicle],” State v. C

13
Schuster v. New Mexico Dep't. of Taxation & Revenuegreen
nm · 2012 · cited in 2 New Mexico opinions naming this issue, 2014–2017
2 sentences

2017See, e.g., Schuster v. N.M. 16 Dep’t of Taxation & Revenue, 2012-NMSC-025, ¶¶ 30-31 , 283 P.3d 288 (observing 17 that probable cause to arrest for DWI existed based on the defendant’s bloodshot, 18 watery eyes, odor of alcohol, admission to drinking, and poor performance on field 19 sobriety tests); State v. Granillo-Macias, 2008-NMCA-021, ¶ 12 , 143 N.M. 455 , 176 2 1 P.3d 1187 (holding that an officer had probable cause to arrest for DWI where the 2 defendant smelled of alcohol, was unsteady on his feet, and did not perform field 3 sobriety tests well); State v. Jones, 1998-NMCA-076, ¶ 10 ,

2014Such 3 1 observations are sufficient to satisfy the probable cause requirement. [DS 3-6] See, 2 e.g., Schuster v. State Dep’t of Taxation & Revenue, 2012-NMSC-025, ¶¶ 30-31 , 283 3 P.3d 288 (observing that probable cause to arrest for DWI existed based on the 4 defendant’s bloodshot watery eyes, odor of alcohol, admission to drinking, and poor 5 performance on field sobriety tests); State v. Granillo-Macias, 2008-NMCA-021 , ¶ 6 12, 143 N.M. 455 , 176 P.3d 1187 (holding that an officer had probable cause to arrest 7 for DWI where the defendant smelled of alcohol, was unsteady on his feet, and d

12
Whren v. United Statesgreen
scotus · 1996 · cited in 2 New Mexico opinions naming this issue, 2005–2008
2 sentences

2008See Whren, 517 U.S. at 813 , 116 S.Ct. 1769 ; LaFave, Routine Traffic Stop, supra, at 1861.

2008See Whren, 517 U.S. at 813 , 116 S.Ct. 1769 ; LaFave, Routine Traffic Stop, supra, at 1861.

12
State v. Wintongreen
nmctapp · 2009 · cited in 1 New Mexico opinions naming this issue, 2025–2025
1 sentence

2025However, the Summers exception to the probable cause requirement is limited to residents and “cannot reasonably be extended to those merely present on the premises.” Graves, 1994-NMCA-151 , ¶ 12 (discussing the Summers exception). {9} In Graves, this Court adopted the “presence plus” approach, which prohibits the detention of nonresidents during residence searches unless there are articulable facts “that would render a detention reasonable under the circumstances.” Id. ¶ 14; see also Winton, 2010-NMCA-020, ¶ 13 (“[A] visitor’s mere presence [is] not sufficient to justify the detention or searc

11
State v. Leongreen
nmctapp · 2012 · cited in 1 New Mexico opinions naming this issue, 2023–2023
1 sentence

2023See Leon, 2013-NMCA-011, ¶ 37 (stating that sufficient evidence to support a single probation violation supports affirmance of a district court's revocation of probation). {7} For the reasons set forth above, we affirm. {8} IT IS SO ORDERED.

11
Durham v. Guestgreen
nm · 2009 · cited in 1 New Mexico opinions naming this issue, 2020–2020
2 sentences

2020See, e.g., DeVaney, 1998-NMSC- 001, ¶ 44 (quoting comment j to Restatement (Second) of Torts Section 674 for the proposition that “[w]hether a withdrawal or an abandonment constitutes a final termination of the case in favor of the person against whom the proceedings are brought and whether the withdrawal is evidence of a lack of probable cause for their initiation, depends upon the circumstances under which the proceedings are withdrawn”); see also DeVaney, 1998-NMSC-001, ¶ 41 (relying on Restatement (Second) of Torts Sections 681B(1)(c) and 681B(2)(a) (1977) for the proposition that probable

2020Plaintiffs offer no reason why the Restatement’s framework should be rejected here. {39} Plaintiffs argue that our Supreme Court, in Durham, 2009-NMSC-007, ¶ 29 , “held that lack of probable cause is only a required element for an abuse of process claim that occurs at the initiation of a claim.” But this is incorrect; Durham simply held that a plaintiff alleging a procedural impropriety or wrongful use of proceedings (the second type of misuse of process) need not have initiated judicial proceedings.

11
DeVaney v. Thriftway Marketing Corp.red
nm · 1997 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020See, e.g., DeVaney, 1998-NMSC- 001, ¶ 44 (quoting comment j to Restatement (Second) of Torts Section 674 for the proposition that “[w]hether a withdrawal or an abandonment constitutes a final termination of the case in favor of the person against whom the proceedings are brought and whether the withdrawal is evidence of a lack of probable cause for their initiation, depends upon the circumstances under which the proceedings are withdrawn”); see also DeVaney, 1998-NMSC-001, ¶ 41 (relying on Restatement (Second) of Torts Sections 681B(1)(c) and 681B(2)(a) (1977) for the proposition that probable

11
Ray MARSHALL, Secretary of Labor, Plaintiff-Appellant, v. HORN SEED COMPANY, INC., Respondent-Appelleegreen
ca10 · 1981 · cited in 1 New Mexico opinions naming this issue, 2019–2019
1 sentence

2019While “[a]n administrative warrant application based upon specific evidence is more analogous to an application for a criminal search warrant than to an application for a search warrant under a regulatory scheme[,]” Marshall v. Horn Seed Co., 647 F.2d 96, 101 (10th Cir. 1981), the probable cause standard in administrative cases differs from the standard in criminal cases.

11
Harjo v. City of Albuquerquegreen
nmd · 2018 · cited in 1 New Mexico opinions naming this issue, 2018–2018
1 sentence

2018See Harjo v. City of Albuquerque, 307 F. Supp. 3d 1163, 1210 (D.N.M. 2018), modified on reconsideration by 326 F. Supp. 3d 1145 (D.N.M. 2018). 8 nuances of the circumstances presented, critically, the seriousness of the crime.

11
State v. Skippingsgreen
nmctapp · 2014 · cited in 1 New Mexico opinions naming this issue, 2017–2017
1 sentence

2017Defendant told the officer that there was marijuana inside a blue backpack 16 in the trunk of the car. [RP 76] The officer requested and received consent from 17 Defendant to search the vehicle. [RP 62, 82] The officer asked for the passenger’s 18 license and instructed Defendant and the passenger to stand on the shoulder of the 19 road about thirty yards away. [RP 76] Moments later three officers arrived to assist 20 with security and the search. [Id.] The blue backpack was found and contained 5 1 marijuana, and a small amount of cocaine, a pipe, and more marijuana was discovered 2 on the rea

11
State v. Marquezgreen
nm · 2009 · cited in 1 New Mexico opinions naming this issue, 2014–2014
2 sentences

2014In her memorandum in opposition Defendant 9 contends that the foregoing considerations should not be deemed sufficient to give rise 10 to probable cause to arrest, in light of her compliance with many of the officer’s 11 instructions as well as the existence of alternative explanations for certain aspects of 12 the behavioral evidence. [MIO 10-12] However, “[a]n appellate court does not 13 evaluate the evidence to determine whether some hypothesis could be designed which 14 is consistent with a finding of innocence.” State v. Sutphin, 1988-NMSC-031 , ¶ 21, 15 107 N.M. 126 , 753 P.2d 1314 ; see

2014In her memorandum in opposition Defendant 9 contends that the foregoing considerations should not be deemed sufficient to give rise 10 to probable cause to arrest, in light of her compliance with many of the officer’s 11 instructions as well as the existence of alternative explanations for certain aspects of 12 the behavioral evidence. [MIO 10-12] However, “[a]n appellate court does not 13 evaluate the evidence to determine whether some hypothesis could be designed which 14 is consistent with a finding of innocence.” State v. Sutphin, 1988-NMSC-031 , ¶ 21, 15 107 N.M. 126 , 753 P.2d 1314 ; see

11
Meiboom v. Watsongreen
nm · 2000 · cited in 1 New Mexico opinions naming this issue, 2010–2010
11
State v. Gutierrezgreen
nmctapp · 1995 · cited in 1 New Mexico opinions naming this issue, 2004–2004
11
Minnesota v. Murphygreen
scotus · 1984 · cited in 1 New Mexico opinions naming this issue, 2004–2004
11
State v. Lucerogreen
nm · 1962 · cited in 1 New Mexico opinions naming this issue, 2004–2004
11
State v. Garciagreen
nm · 1968 · cited in 1 New Mexico opinions naming this issue, 2004–2004
11
State v. Gravesgreen
nmctapp · 1994 · cited in 1 New Mexico opinions naming this issue, 2000–2000
11
State v. Coyazogreen
nmctapp · 1997 · cited in 1 New Mexico opinions naming this issue, 2000–2000
11
State v. Willisgreen
nm · 1997 · cited in 1 New Mexico opinions naming this issue, 1999–1999
11
State v. TYWAYNE H.green
nmctapp · 1997 · cited in 1 New Mexico opinions naming this issue, 1999–1999
11
State v. Andersongreen
nmctapp · 1988 · cited in 1 New Mexico opinions naming this issue, 1999–1999
11
State v. Gallowaygreen
nmctapp · 1993 · cited in 1 New Mexico opinions naming this issue, 1999–1999
11
State v. Warrengreen
nmctapp · 1985 · cited in 1 New Mexico opinions naming this issue, 1999–1999
11
People v. Bowersgreen
nyappterm · 1974 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
State v. Younggreen
ga · 1975 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
State v. Rossgreen
ariz · 1994 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Cason v. Cookgreen
ca8 · 1987 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
FP v. Stategreen
fladistctapp · 1988 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Michigan v. Dorangreen
scotus · 1978 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Picha v. Wielgosgreen
ilnd · 1976 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Corlett v. Smithgreen
nmctapp · 1987 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Martens Ex Rel. Martens v. District No. 220, Board of Educationgreen
ilnd · 1985 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Mariposa Development Co. v. Stoddardgreen
arizctapp · 1985 · cited in 1 New Mexico opinions naming this issue, 1994–1994
11
Commonwealth v. Edmundsgreen
pa · 1991 · cited in 1 New Mexico opinions naming this issue, 1991–1991
11
United States v. Charles N. Matthewsgreen
ca10 · 1980 · cited in 1 New Mexico opinions naming this issue, 1989–1989
11

Distinguished, questioned or overruled (2)

CaseNegativeCited
People v. Dilworthgreen
ill · 1996 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11
Polur v. Grievance Committee for the Southern District of New Yorkgreen
scotus · 1996 · cited in 1 New Mexico opinions naming this issue, 1997–1997
11

Also cited on this issue (35)

CaseCitedYears
State v. Nyce green
nm · 2006
2 sentences

2009The Court noted that "the probable cause inquiry should be `particularly exacting' when the conduct observed by an officer is consistent with lawful activity, and this is so `regardless of an officer's qualifications and experience.'" Id. ¶ 10 (quoting State v. Nyce, 2006-NMSC-026, ¶ 14 , 139 N.M. 647 , 137 P.3d 587 ).

2009The Court noted that "the probable cause inquiry should be `particularly exacting' when the conduct observed by an officer is consistent with lawful activity, and this is so `regardless of an officer's qualifications and experience.'" Id. ¶ 10 (quoting State v. Nyce, 2006-NMSC-026, ¶ 14 , 139 N.M. 647 , 137 P.3d 587 ).

32008–2009
State v. Nyce green
nm · 2006
2 sentences

2009The Court noted that “the probable cause inquiry should be ‘particularly exacting’ when the conduct observed by an officer is consistent with lawful activity, and this is so ‘regardless of an officer’s qualifications and experience.’ ” Id. ¶ 10 (quoting State v. Nyce, 2006-NMSC-026, ¶ 14 , 139 N.M. 647 , 137 P.3d 587 ).

2009The Court noted that "the probable cause inquiry should be `particularly exacting' when the conduct observed by an officer is consistent with lawful activity, and this is so `regardless of an officer's qualifications and experience.'" Id. ¶ 10 (quoting State v. Nyce, 2006-NMSC-026, ¶ 14 , 139 N.M. 647 , 137 P.3d 587 ).

32008–2009
State v. Neal green
nm · 2007
2 sentences

2023We have 8 previously explained that “reasonable suspicion can arise from wholly lawful 9 conduct.” State v. Neal, 2007-NMSC-043, ¶ 28 , 142 N.M. 176 , 164 P.3d 57 (internal 10 quotation marks and citation omitted).

2023We have 8 previously explained that “reasonable suspicion can arise from wholly lawful 9 conduct.” State v. Neal, 2007-NMSC-043, ¶ 28 , 142 N.M. 176 , 164 P.3d 57 (internal 10 quotation marks and citation omitted).

22023–2023
State v. Sanchez green
nmctapp · 2015
2 sentences

2021State v. Sanchez, 2015-NMCA-084, ¶ 14 , 355 P.3d 795 . {5} Here, Officer Jeffrey Zamorano testified that he was dispatched to a single-car accident, where he made contact with Defendant. [MIO 2] Defendant stated that he was the driver and had consumed alcohol prior to the crash. [MIO 2] Officer Zamorano also observed that Defendant had blood-shot watery eyes and smelled of alcohol. [MIO 2] Officer Zamorano testified that he administered standard field sobriety tests (FST’s), and indicated that Defendant had difficulty in complying. [MIO 2] Defendant was then placed under arrest. [DS 2] {6} Our

2017Cf. 12 State v. Sanchez, 2015-NMCA-084, ¶ 13-14 , 355 P.3d 795 (discussing plain-view 13 exception and probable cause). 14 {6} In the motion to amend, Defendant does not make the same argument that he 15 made below, that the description of the items was not sufficiently specific to alert 16 officers executing the search warrant as to which property was subject to seizure. [RP 17 74] That argument therefore appears to have been abandoned; but to the extent 18 Defendant may be intending to raise that argument, we believe, as did the district 19 court [RP 138], that the reference to items stolen

22017–2021
State v. Ogden green
nm · 1994
2 sentences

2004As a result, a probable cause standard applies at the pretrial determination, and “the State will defeat the motion if it proves that there is probable cause to believe an aggravating circumstance is present.” Id. at 240 , 880 P.2d at 851 .

2004As a result, a probable cause standard applies at the pretrial determination, and “the State will defeat the motion if it proves that there is probable cause to believe an aggravating circumstance is present.” Id. at 240 , 880 P.2d at 851 .

22004–2006
Atwater v. City of Lago Vista green
scotus · 2001
2 sentences

2006The Court preferred to remain with what it considered the traditional probable cause standard for constitutional reasonableness, rather than to “mint a new rule of constitutional law on the understanding that when historical practice fails to speak conclusively to a claim grounded on the Fourth Amendment, courts are left to strike a current balance between individual and societal interests by subjecting particular contemporary circumstances to traditional standards of reasonableness.” Id. at 345^16, 121 S.Ct. 1536 .

2006The Court preferred to remain with what it considered the traditional probable cause standard for constitutional reasonableness, rather than to “mint a new rule of constitutional law on the understanding that when historical practice fails to speak conclusively to a claim grounded on the Fourth Amendment, courts are left to strike a current balance between individual and societal interests by subjecting particular contemporary circumstances to traditional standards of reasonableness.” Id. at 345^16, 121 S.Ct. 1536 .

22005–2006
New Jersey v. T. L. O. green
scotus · 1985
2 sentences

2000Further, .strict adherence to a probable cause requirement could not be justified in light of “the substantial need of teachers and administrators for freedom to maintain order in the schools.” Id. at 341 , 105 S.Ct. 733 .

2000Further, .strict adherence to a probable cause requirement could not be justified in light of “the substantial need of teachers and administrators for freedom to maintain order in the schools.” Id. at 341 , 105 S.Ct. 733 .

21998–2000
State v. Ochoa green
nm · 2004
2 sentences

2026II, § 10 and State v. Ochoa, 2004-NMSC-023, ¶ 9 , 135 N.M. 781 , 93 P.3d 1286 (explaining that under the probable cause requirement for a lawful arrest, a law enforcement officer must establish “facts and circumstances [that] warrant a belief that the accused had committed an offense, or is committing an offense”), with N.M.

2026II, § 10 and State v. Ochoa, 2004-NMSC-023, ¶ 9 , 135 N.M. 781 , 93 P.3d 1286 (explaining that under the probable cause requirement for a lawful arrest, a law enforcement officer must establish “facts and circumstances [that] warrant a belief that the accused had committed an offense, or is committing an offense”), with N.M.

12026–2026
State v. Martinez green
nmctapp · 1996
2 sentences

2025However, the Summers exception to the probable cause requirement is limited to residents and “cannot reasonably be extended to those merely present on the premises.” Graves, 1994-NMCA-151 , ¶ 12 (discussing the Summers exception). {9} In Graves, this Court adopted the “presence plus” approach, which prohibits the detention of nonresidents during residence searches unless there are articulable facts “that would render a detention reasonable under the circumstances.” Id. ¶ 14; see also Winton, 2010-NMCA-020, ¶ 13 (“[A] visitor’s mere presence [is] not sufficient to justify the detention or searc

2025However, the Summers exception to the probable cause requirement is limited to residents and “cannot reasonably be extended to those merely present on the premises.” Graves, 1994-NMCA-151 , ¶ 12 (discussing the Summers exception). {9} In Graves, this Court adopted the “presence plus” approach, which prohibits the detention of nonresidents during residence searches unless there are articulable facts “that would render a detention reasonable under the circumstances.” Id. ¶ 14; see also Winton, 2010-NMCA-020, ¶ 13 (“[A] visitor’s mere presence [is] not sufficient to justify the detention or searc

12025–2025
State v. Cassola green
nmctapp · 2001
2 sentences

2025However, the Summers exception to the probable cause requirement is limited to residents and “cannot reasonably be extended to those merely present on the premises.” Graves, 1994-NMCA-151 , ¶ 12 (discussing the Summers exception). {9} In Graves, this Court adopted the “presence plus” approach, which prohibits the detention of nonresidents during residence searches unless there are articulable facts “that would render a detention reasonable under the circumstances.” Id. ¶ 14; see also Winton, 2010-NMCA-020, ¶ 13 (“[A] visitor’s mere presence [is] not sufficient to justify the detention or searc

2025However, the Summers exception to the probable cause requirement is limited to residents and “cannot reasonably be extended to those merely present on the premises.” Graves, 1994-NMCA-151 , ¶ 12 (discussing the Summers exception). {9} In Graves, this Court adopted the “presence plus” approach, which prohibits the detention of nonresidents during residence searches unless there are articulable facts “that would render a detention reasonable under the circumstances.” Id. ¶ 14; see also Winton, 2010-NMCA-020, ¶ 13 (“[A] visitor’s mere presence [is] not sufficient to justify the detention or searc

12025–2025
State v. Jason L. green
nm · 2000
2 sentences

2024Reviewing the totality of the circumstances and considering the Deputy’s testimony about his experience and specialized training in interdiction and narcotics recognition, each of the facts available to Deputy Salazar before he questioned Defendant about his travel were sufficient to establish reasonable suspicion of criminal activity. {11} We agree with the Court of Appeals and Defendant’s contention that, at the suppression hearing, Deputy Salazar should not have relied on facts discovered after the expansion of the stop to “justify expanding the scope of the detention to ask the questions i

2024Reviewing the totality of the circumstances and considering the Deputy’s testimony about his experience and specialized training in interdiction and narcotics recognition, each of the facts available to Deputy Salazar before he questioned Defendant about his travel were sufficient to establish reasonable suspicion of criminal activity. {11} We agree with the Court of Appeals and Defendant’s contention that, at the suppression hearing, Deputy Salazar should not have relied on facts discovered after the expansion of the stop to “justify expanding the scope of the detention to ask the questions i

12024–2024
Berger v. Sonneland green
washctapp · 2000
1 sentence

2017See, e.g., Schuster v. N.M. 16 Dep’t of Taxation & Revenue, 2012-NMSC-025, ¶¶ 30-31 , 283 P.3d 288 (observing 17 that probable cause to arrest for DWI existed based on the defendant’s bloodshot, 18 watery eyes, odor of alcohol, admission to drinking, and poor performance on field 19 sobriety tests); State v. Granillo-Macias, 2008-NMCA-021, ¶ 12 , 143 N.M. 455 , 176 2 1 P.3d 1187 (holding that an officer had probable cause to arrest for DWI where the 2 defendant smelled of alcohol, was unsteady on his feet, and did not perform field 3 sobriety tests well); State v. Jones, 1998-NMCA-076, ¶ 10 ,

12017–2017
State v. Jones green
nmctapp · 1998
2 sentences

2017See, e.g., Schuster v. N.M. 16 Dep’t of Taxation & Revenue, 2012-NMSC-025, ¶¶ 30-31 , 283 P.3d 288 (observing 17 that probable cause to arrest for DWI existed based on the defendant’s bloodshot, 18 watery eyes, odor of alcohol, admission to drinking, and poor performance on field 19 sobriety tests); State v. Granillo-Macias, 2008-NMCA-021, ¶ 12 , 143 N.M. 455 , 176 2 1 P.3d 1187 (holding that an officer had probable cause to arrest for DWI where the 2 defendant smelled of alcohol, was unsteady on his feet, and did not perform field 3 sobriety tests well); State v. Jones, 1998-NMCA-076, ¶ 10 ,

2017See, e.g., Schuster v. N.M. 16 Dep’t of Taxation & Revenue, 2012-NMSC-025, ¶¶ 30-31 , 283 P.3d 288 (observing 17 that probable cause to arrest for DWI existed based on the defendant’s bloodshot, 18 watery eyes, odor of alcohol, admission to drinking, and poor performance on field 19 sobriety tests); State v. Granillo-Macias, 2008-NMCA-021, ¶ 12 , 143 N.M. 455 , 176 2 1 P.3d 1187 (holding that an officer had probable cause to arrest for DWI where the 2 defendant smelled of alcohol, was unsteady on his feet, and did not perform field 3 sobriety tests well); State v. Jones, 1998-NMCA-076, ¶ 10 ,

12017–2017
Weststar Mortgage Corp. v. Jackson green
nm · 2002
2 sentences

2015Weststar Mortg. 10 Corp. v. Jackson, 2003-NMSC-002, ¶ 16 , 133 N.M. 114 , 61 P.3d 823 (“Probable 11 cause . . . is to be judged by facts as they appeared at the time, not by later-discovered 12 facts.” (internal quotation marks and citation omitted)).

2015Weststar Mortg. 10 Corp. v. Jackson, 2003-NMSC-002, ¶ 16 , 133 N.M. 114 , 61 P.3d 823 (“Probable 11 cause . . . is to be judged by facts as they appeared at the time, not by later-discovered 12 facts.” (internal quotation marks and citation omitted)).

12015–2015
State v. Sutphin green
nm · 1988
2 sentences

2014In her memorandum in opposition Defendant 9 contends that the foregoing considerations should not be deemed sufficient to give rise 10 to probable cause to arrest, in light of her compliance with many of the officer’s 11 instructions as well as the existence of alternative explanations for certain aspects of 12 the behavioral evidence. [MIO 10-12] However, “[a]n appellate court does not 13 evaluate the evidence to determine whether some hypothesis could be designed which 14 is consistent with a finding of innocence.” State v. Sutphin, 1988-NMSC-031 , ¶ 21, 15 107 N.M. 126 , 753 P.2d 1314 ; see

2014In her memorandum in opposition Defendant 9 contends that the foregoing considerations should not be deemed sufficient to give rise 10 to probable cause to arrest, in light of her compliance with many of the officer’s 11 instructions as well as the existence of alternative explanations for certain aspects of 12 the behavioral evidence. [MIO 10-12] However, “[a]n appellate court does not 13 evaluate the evidence to determine whether some hypothesis could be designed which 14 is consistent with a finding of innocence.” State v. Sutphin, 1988-NMSC-031 , ¶ 21, 15 107 N.M. 126 , 753 P.2d 1314 ; see

12014–2014
Dunaway v. New York green
scotus · 1979
12005–2005
Richards v. Wisconsin green
scotus · 1997
12005–2005
United States v. Knights green
scotus · 2001
12004–2004
State v. Bunnell green
nmctapp · 1983
12001–2001
State v. Cordova green
nm · 1989
12000–2000
Vernonia School District 47J v. Acton green
scotus · 1995
11998–1998
cluster 377082 green
ca8 · 1980
11997–1997
Terry v. Ohio green
scotus · 1968
11997–1997
Gerstein v. Pugh green
scotus · 1975
11997–1997
Morrissey v. Brewer green
scotus · 1972
11997–1997
State v. Carrasco green
arizctapp · 1985
11994–1994
United States v. Place green
scotus · 1983
11994–1994
People v. David green
michctapp · 1982
11991–1991
State v. Greyeyes green
nmctapp · 1987
11991–1991
State v. Harrison green
nmctapp · 1980
11985–1985
Ybarra v. Illinois green
scotus · 1980
11985–1985
United States v. Vernon Willis Bowman, Jr. green
ca10 · 1973
11982–1982
United States v. John Rumpf, Joanne Hanson, Gloria Masters, and Gary James Griffin green
ca10 · 1978
11982–1982
Ochoa v. Estelle green
scotus · 1978
11982–1982
Woodward v. Southern Ry. Co. green
sc · 1914
11982–1982

Statutes the citing opinions construe

NM § N.M. Stat. § 30-31-22 (4) NM § N.M. Stat. § 31-20A-5 (4) NM § N.M. Stat. § 30-31-23 (3) USC § 42u.s.c.1983 (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

IL 408 (1966–2026) CA 362 (1955–2026) OH 284 (1978–2026) MA 271 (1967–2026) TX 242 (1927–2026) CT 237 (1969–2026) PA 224 (1967–2026) NY 192 (1959–2026) WA 159 (1973–2026) WI 141 (1970–2026) NJ 141 (1978–2026) FL 137 (1973–2025) IN 136 (1971–2025) MI 109 (1972–2026) MD 98 (1973–2026) MN 93 (1975–2026) VA 93 (1975–2026) AL 86 (1937–2024) NC 85 (1974–2026) OR 81 (1976–2026) ID 77 (1978–2026) DC 76 (1970–2026) KS 75 (1975–2024) GA 68 (1969–2026) CO 68 (1971–2025) AZ 61 (1971–2025) MO 57 (1970–2024) UT 56 (1980–2026) IA 54 (1978–2026) ME 53 (1970–2023) LA 51 (1976–2020) TN 51 (1972–2025) NM 51 (1974–2026) MT 50 (1973–2025) AR 41 (1973–2024) ND 37 (1971–2021) KY 36 (1968–2026) NH 34 (1974–2024) RI 31 (1981–2026) WV 30 (1980–2026) MS 29 (1988–2023) DE 27 (1969–2026) SC 26 (2001–2025) AK 26 (1977–2025) NV 24 (1968–2022) VT 20 (1971–2020) WY 19 (1976–2025) NE 18 (1981–2024) SD 17 (1975–2019) HI 17 (1973–2022) VI 11 (1981–2014) OK 9 (1953–2006) MP 2 (2023–2024)

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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