first and third factors (New Mexico) · Go Syfert
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first and third factors in New Mexico

6 New Mexico opinions name it 1 courts 2012–2025 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 (7)

CaseFollowedCited
State v. Sotogreen
nmctapp · 2008 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020Compare Soto, 2008-NMCA-032, ¶¶ 26-27 (excluding evidence obtained after an officer discovers and executes a preexisting arrest warrant, because the first and third factors weighed in favor of suppression), with Strieff, 136 S. Ct. at 2063 (“Although the illegal stop was close in time to [the defendant’s] arrest, that consideration is outweighed by two factors supporting the [s]tate.”), Tapia, 2018-NMSC-017, ¶¶ 35, 37-38 (concluding exclusion of the evidence is unnecessary when the first factor weighs in favor of suppression but the second and third factors weigh in favor of attenuation), and

11
State v. Tapiagreen
nm · 2018 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020Compare Soto, 2008-NMCA-032, ¶¶ 26-27 (excluding evidence obtained after an officer discovers and executes a preexisting arrest warrant, because the first and third factors weighed in favor of suppression), with Strieff, 136 S. Ct. at 2063 (“Although the illegal stop was close in time to [the defendant’s] arrest, that consideration is outweighed by two factors supporting the [s]tate.”), Tapia, 2018-NMSC-017, ¶¶ 35, 37-38 (concluding exclusion of the evidence is unnecessary when the first factor weighs in favor of suppression but the second and third factors weigh in favor of attenuation), and

11
State v. Edwardsgreen
nmctapp · 2019 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020Compare Soto, 2008-NMCA-032, ¶¶ 26-27 (excluding evidence obtained after an officer discovers and executes a preexisting arrest warrant, because the first and third factors weighed in favor of suppression), with Strieff, 136 S. Ct. at 2063 (“Although the illegal stop was close in time to [the defendant’s] arrest, that consideration is outweighed by two factors supporting the [s]tate.”), Tapia, 2018-NMSC-017, ¶¶ 35, 37-38 (concluding exclusion of the evidence is unnecessary when the first factor weighs in favor of suppression but the second and third factors weigh in favor of attenuation), and

11
Utah v. Strieffgreen
scotus · 2016 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020Compare Soto, 2008-NMCA-032, ¶¶ 26-27 (excluding evidence obtained after an officer discovers and executes a preexisting arrest warrant, because the first and third factors weighed in favor of suppression), with Strieff, 136 S. Ct. at 2063 (“Although the illegal stop was close in time to [the defendant’s] arrest, that consideration is outweighed by two factors supporting the [s]tate.”), Tapia, 2018-NMSC-017, ¶¶ 35, 37-38 (concluding exclusion of the evidence is unnecessary when the first factor weighs in favor of suppression but the second and third factors weigh in favor of attenuation), and

11
State v. Garzagreen
nm · 2009 · cited in 1 New Mexico opinions naming this issue, 2015–2015
1 sentence

2015See Garza, 2009-NMSC-038, ¶ 2 (stating that the length of delay 9 necessary to trigger the speedy trial inquiry is eighteen months for complex cases). 10 The district court weighed the length-of-delay factor “heavily against the State[.]” 11 Additionally, owing to what the district court characterized as Defendant’s “mostly 12 pro forma” assertions of her right to a speedy trial, it weighed the assertion-of-right 13 factor “lightly against the State.” Because the State has not attacked the district 14 court’s findings in regard to the first and third factors, they are conclusive.

11
Oldham v. Oldhamgreen
nm · 2011 · cited in 1 New Mexico opinions naming this issue, 2013–2013
2 sentences

2013Id.; see Oldham v. Oldham, 2011-NMSC-007 , 149 N.M. 215 , 247 P.3d 736 . 16 {9} The district court apparently agreed with Wife that the first and third factors 17 supported dismissal.

2013Id.; see Oldham v. Oldham, 2011-NMSC-007 , 149 N.M. 215 , 247 P.3d 736 . 16 {9} The district court apparently agreed with Wife that the first and third factors 17 supported dismissal.

11
Beavers v. Johnson Controls World Services, Inc.green
nm · 1994 · cited in 1 New Mexico opinions naming this issue, 2012–2012
2 sentences

2012See Beavers, 118 N.M. at 399 , 881 P.2d at 1384 .

2012See Beavers, 118 N.M. at 399 , 881 P.2d at 1384 .

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 (4)

CaseCitedYears
State v. Garcia green
nm · 2005
1 sentence

2025Garcia, 2005-NMSC-038, ¶ 7 .

12025–2025
State v. Arvizo green
nm · 2018
1 sentence

2021We explain. {17} Examining the first factor, whether Defendant could have committed the greater offense without also committing the lesser offense, we conclude that the elements of the crimes differ in such a way that each may be committed without necessarily committing the other. {18} In State v. Arvizo, our Supreme Court discussed the differences between third- degree and second-degree CSCM with child victims aged thirteen to eighteen years. 2018-NMSC-026, ¶ 14 , 417 P.3d 384 .

12021–2021
State v. Arvizo green
nm · 2018
1 sentence

2021We explain. {17} Examining the first factor, whether Defendant could have committed the greater offense without also committing the lesser offense, we conclude that the elements of the crimes differ in such a way that each may be committed without necessarily committing the other. {18} In State v. Arvizo, our Supreme Court discussed the differences between third- degree and second-degree CSCM with child victims aged thirteen to eighteen years. 2018-NMSC-026, ¶ 14 , 417 P.3d 384 .

12021–2021
State v. Meadors green
nm · 1995
1 sentence

2021Id. {16} We need only analyze the first and third factors to conclude that Defendant was not entitled to a lesser included offense instruction on third-degree CSCM under thirteen.

12021–2021

Where else courts name it

TX 17 (1992–2024) CA 13 (1979–2026) WA 13 (1988–2021) IL 10 (1976–2023) NM 6 (2012–2025) OR 5 (2018–2024) WI 5 (2018–2024) MI 4 (2014–2026) MN 3 (2012–2014) MD 3 (2000–2017) NV 3 (2017–2017) UT 3 (2008–2020) NH 3 (2008–2023) SC 2 (2012–2022) DE 2 (2015–2023) KS 2 (2010–2024) GA 2 (2003–2023) ND 2 (2012–2012) PA 2 (2024–2024) MA 2 (2011–2021) MT 2 (2007–2021) OH 2 (2017–2021) CT 2 (1986–1996) SD 2 (2004–2016) MO 2 (1986–1997) HI 2 (2004–2005) NY 2 (1965–2022) ME 2 (2014–2024)

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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