New Mexico v. Paananen
Annotate this CaseIn this case, police officers made their arrest for shoplifting at the scene of the crime, without any prior opportunity to secure a warrant. Surveillance cameras at Sportsman’s Warehouse in Albuquerque caught defendant Ernest Paananen placing two flashlights under his jacket and then leaving the store without paying. Moments later, the store’s loss prevention team apprehended defendant and returned him to the store. The loss prevention team placed defendant in a back room, frisked him, and called the police. During the frisk, a loss prevention employee placed defendant’s possessions on the table, along with the stolen flashlights. The employee did not go through Defendant’s backpack. Albuquerque Police Department Officers Cole Knight and Andrew Hsu arrived at the store. Defendant was immediately handcuffed, and officers searched Defendant’s backpack and found hypodermic needles. When questioned about the needles, defendant admitted that he had tried to use drugs the day before but said he did not possess any drugs. While waiting for a copy of the surveillance video, Officer Knight searched through defendant’s possessions on the table and found a cigarette pack, and in looking inside the pack, discovered a substance believed to be heroin. Along with shoplifting, the State charged defendant with possession of a controlled substance and possession of drug paraphernalia. Defendant sought to suppress all evidence seized at the store, arguing that the officers conducted an unreasonable, warrantless search. The Court of Appeals affirmed the suppression. The Supreme Court, after review, reversed the Court of Appeals, finding that though without a warrant, defendant's arrest was reasonable under the New Mexico Constitution. "The subsequent warrantless search of Defendant fits a judicially recognized exception to the warrant requirement and was therefore also constitutionally reasonable."
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