State v. Ramirez

CourtNew Mexico Court of Appeals
DecidedApril 5, 2010
Docket28,481
StatusUnpublished

This text of State v. Ramirez (State v. Ramirez) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Ramirez, (N.M. Ct. App. 2010).

Opinion

1 This memorandum opinion was not selected for publication in the New Mexico Reports. Please 2 see Rule 12-405 NMRA for restrictions on the citation of unpublished memorandum opinions. 3 Please also note that this electronic memorandum opinion may contain computer-generated 4 errors or other deviations from the official paper version filed by the Court of Appeals and does 5 not include the filing date. 6 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

7 STATE OF NEW MEXICO,

8 Plaintiff-Appellee,

9 v. NO. 28,481

10 JOHN RAMIREZ,

11 Defendant-Appellant.

12 APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY 13 Albert S. “Pat” Murdoch, District Judge

14 Gary K. King, Attorney General 15 Santa Fe, NM 16 Jacqueline R. Medina, Assistant Attorney General 17 Albuquerque, NM

18 for Appellee

19 Hugh W. Dangler, Chief Public Defender 20 Will O’Connell, Assistant Appellate Defender 21 Santa Fe, NM

22 for Appellant 1 MEMORANDUM OPINION

2 ROBLES, Judge.

3 John Ramirez (Defendant) appeals the district court’s denial of his motion to

4 suppress. Defendant asserts protection under both the federal and state constitutions

5 and argues that a police officer, investigating a parking violation, may not further

6 detain an individual by requesting a license and registration and, in doing so, results

7 in an unconstitutional detention, which must result in the suppression of the evidence.

8 In doing so, Defendant asks this Court to make a distinction between how we treat

9 parking violations and moving violations. We conclude that our law does not support

10 such a distinction. Furthermore, applying our seizure analysis, we conclude that there

11 was nothing unlawful about Defendant’s stop. Defendant does not explain how our

12 analysis of the New Mexico Constitution should be different than its federal

13 counterpart. Because of the limited manner in which Defendant addresses this

14 argument and our duty to resist making arguments for parties, we decline to discuss

15 any possible distinctions between the two formative documents. Accordingly, we

16 affirm.

17 I. BACKGROUND

18 At the hearing on the motion to suppress, the only witness presented was

19 Officer Andrew Feist, who testified as follows. On March 17, 2006, Officer Feist was

2 1 on routine mountain bike patrol when he noticed Defendant’s illegally parked vehicle.

2 The vehicle was not running and was double-parked in a handicapped space, blocking

3 the handicapped ramp. The officer began talking with an individual in the vicinity and

4 inquired whether he was the owner of the illegally parked vehicle, “at which time[,]

5 he told me he was not.” As the officer was talking with the individual, the officer

6 “heard car doors slam and the engine . . . start up.”

7 Officer Feist returned to the vehicle and saw Defendant in the driver’s seat with

8 another individual in the passenger’s seat. The officer identified himself and asked

9 Defendant whether he had a handicap parking placard, to which Defendant replied he

10 did not. It was then that the officer asked Defendant for his license and registration,

11 so that he could write him a citation. As Defendant leaned towards the glove

12 compartment, the officer “leaned into the vehicle and looked straight down into the

13 driver’s door [but without placing his] head inside the vehicle, just directly alongside,

14 to look down there.” In the armrest of the door, there was “a clear plastic baggie that

15 contained a brown substance that, through [the officer’s] training and experience, was

16 consistent with heroin. Alongside of that, there was a one-dollar bill that was rolled

17 up and had both ends of it burnt.” The officer stated “[t]hat [a one-dollar bill] is

18 commonly used in the smoking of a narcotic.”

3 1 As a result of this discovery, Defendant was arrested. Officer Feist testified

2 further that his reason for attempting to make contact with the owner of the illegally

3 parked vehicle was to see whether the owner had a handicap placard, or to see if there

4 was some kind of emergency which would justify the vehicle being parked as it was.

5 The district court denied the motion to suppress, and Defendant entered a conditional

6 plea to possession of heroin, reserving his right to appeal the district court’s denial,

7 and was sentenced to eighteen months of supervised probation.

8 II. DISCUSSION

9 “The standard of review for suppression rulings is whether the law was

10 correctly applied to the facts, viewing them in a manner most favorable to the

11 prevailing party.” State v. Jason L., 2000-NMSC-018, ¶ 10, 129 N.M. 119, 2 P.3d

12 856 (internal quotation marks and citation omitted). We will adopt an interpretation

13 of the factual background that is “most favorable to the prevailing party, as long as the

14 facts are supported by substantial evidence.” State v. Vandenberg, 2003-NMSC-030,

15 ¶ 18, 134 N.M. 566, 81 P.3d 19. It is “[a]gainst [the] factual backdrop [that] we

16 evaluate de novo the reasonableness of the conduct of law enforcement officers,

17 considering the totality of the circumstances.” State v. Gutierrez, 2008-NMCA-015,

18 ¶ 4, 143 N.M. 522, 177 P.3d 1096 (filed 2007).

4 1 A. Request for Driver’s Information

2 Defendant argues that a parking violation is different from a moving violation.

3 Defendant also argues that because a parking ticket can be issued without examining

4 a driver’s license or registration, Officer Feist’s request for such documentation was

5 not constitutional.

6 New Mexico cases have previously held that following a lawful stop, a police

7 officer may ask a driver for their driving documentation. State v. Reynolds, 119 N.M.

8 383, 386, 388, 890 P.2d 1315, 1318, 1320 (1995) (noting that individuals have little

9 privacy interests in public documentation and stating that “[i]f a driver invites the

10 attention of a police officer by engaging in unsafe driving conduct, or whenever an

11 officer is reasonably called upon to make contact with a driver . . . , the officer has the

12 right to know with whom he is talking and may check to see that the driver is both

13 licensed and driving a car that is registered and insured”); State v. Rubio,

14 2006-NMCA-067, ¶ 13, 139 N.M. 612, 136 P.3d 1022 (following a lawful vehicle

15 stop, a request for documents in connection with the stop does not violate state or

16 federal constitutions). “Following a valid stop, for a traffic violation, an officer may

17 lawfully continue with a de minimis detention for inquiry into matters reasonably

18 related to the circumstances that initially justified the stop and to check out license,

19 registration, and insurance.” State v. Affsprung, 2004-NMCA-038, ¶ 10, 135 N.M.

5 1 306, 87 P.3d 1088. This applies to situations involving both moving and non-moving

2 vehicles. State v. Williams, 2006-NMCA-062, ¶ 16, 139 N.M. 578, 136 P.3d 579.

3 Our statutory scheme does not distinguish between parking and moving

4 violations in this regard. NMSA 1978, Section 66-7-352.5(A)-(B) (2007) makes it

5 unlawful to park a vehicle in a space reserved for persons with mobility impairment,

6 or to park in such a manner so as to block access to any part of a curb designed for

7 access by persons with mobility impairment. This provision is included as part of the

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Related

State v. Prince
2004 NMCA 127 (New Mexico Court of Appeals, 2004)
State v. Williams
2006 NMCA 062 (New Mexico Court of Appeals, 2006)
State v. Rubio
2006 NMCA 067 (New Mexico Court of Appeals, 2006)
State v. Affsprung
2004 NMCA 038 (New Mexico Court of Appeals, 2004)
State v. Reynolds
890 P.2d 1315 (New Mexico Supreme Court, 1995)
State v. Vandenberg
2003 NMSC 030 (New Mexico Supreme Court, 2003)
State v. Jason L.
2 P.3d 856 (New Mexico Supreme Court, 2000)
State v. Gutierrez
2008 NMCA 015 (New Mexico Court of Appeals, 2007)

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State v. Ramirez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-ramirez-nmctapp-2010.