City of Farmington v. Scott

New Mexico Court of Appeals·Decided January 23, 2017·No. 35,431·Unpublished

Opinion

This memorandum opinion was not selected for publication in the New Mexico Appellate Reports.

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1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO 2 CITY OF FARMINGTON, 3 Plaintiff-Appellee, 4 v. NO. 35,431 5 BILL SCOTT, 6 Defendant-Appellant.

7 APPEAL FROM THE DISTRICT COURT OF SAN JUAN COUNTY 8 Daylene A. Marsh, Judge

9 Office of the City Attorney 10 Russel A. Frost 11 Farmington, NM

12 for Appellee

13 Bennett J. Baur, Chief Public Defender 14 Tania Shahani, Assistant Appellate Defender 15 Santa Fe, NM

16 for Appellant 17 MEMORANDUM OPINION 18 VIGIL, Judge.

1 {1} Defendant challenges the denial of a motion to suppress. We previously issued 2 a notice, proposing to uphold the district court’s determination. Defendant has filed 3 a memorandum in opposition. After due consideration, we affirm. 4 {2} The relevant background information was previously set forth at length, and we 5 will avoid undue reiteration here. To briefly summarize, police officers initiated a 6 traffic stop and detained Defendant based upon an eyewitness report that the 7 perpetrators of an armed robbery had just left the scene in a vehicle of matching 8 description. Defendant does not challenge the validity of the stop. [MIO 13-14] 9 However, he contends that the initial investigatory detention evolved into an 10 impermissible de facto arrest. [MIO 12-15] He further argues that the officers lacked 11 any valid basis for expanding the scope of the inquiry, from the robbery into the 12 ensuing DWI investigation which led to his arrest and conviction. [MIO 7-12] We 13 remain unpersuaded. 14 {3} As described in the notice of proposed summary disposition, [CN 2-5] the 15 initial 45-minute detention, during which time the officers brought the eyewitness to 16 the scene to facilitate a viewing for purposes of identification, [MIO 12-13] was 17 permissible. Given the government’s strong interest in combating violent crime, and 18 given that the officers conducted the investigation with due diligence, that portion of 19 the encounter cannot be characterized as an impermissible de facto arrest. See State

1 v. Werner, 1994-NMSC-025, ¶¶ 14, 17, 20, 117 N.M. 315, 871 P.2d 971 (observing 2 that detention in a patrol car does not constitute an arrest per se that diligence is key, 3 and holding that a 45-minute period of detention during which police brought a 4 witness for purposes of identification was not unreasonable); see generally State v. 5 Skippings, 2014-NMCA-117, ¶ 14, 338 P.3d 128 (setting forth relevant factors in this 6 context). 7 {4} We understand Defendant to contend that the detention should be said to have 8 evolved into a de facto arrest as a consequence of the officers’ failure to release him 9 the moment the eyewitness failed to identify him as one of the perpetrators of the 10 armed robbery. [MIO 14] We disagree. After the portion of the investigation 11 associated with the eyewitness concluded, the officers took statements from Defendant 12 and his passenger. [MIO 13] That process appears to have taken roughly ten minutes. 13 [MIO 13] In light of the fact that Defendant’s vehicle had been placed at the scene at 14 the time of the robbery, the officers’ decision to take his statement and the statement 15 of his passenger was not unreasonable. And although the officers briefly discussed the 16 course of the investigation amongst themselves and ultimately decided that Defendant 17 should be released, those few minutes spent in discussion cannot be regarded as 18 unreasonable or impermissible. See State v. Leyva, 2011-NMSC-009, ¶ 20, 149 N.M.

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Related

State v. Leyva
2011 NMSC 9 (New Mexico Supreme Court, 2011)
State v. Munoz
1998 NMCA 140 (New Mexico Court of Appeals, 1998)
State v. Taylor
1999 NMCA 022 (New Mexico Court of Appeals, 1998)
State v. Werner
871 P.2d 971 (New Mexico Supreme Court, 1994)
State v. Walters
1997 NMCA 013 (New Mexico Court of Appeals, 1996)
State v. Williamson
9 P.3d 70 (New Mexico Court of Appeals, 2000)
State v. Skippings
2014 NMCA 117 (New Mexico Court of Appeals, 2014)