New Mexico v. Crane
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Defendant was charged with trafficking controlled substances and possession of drug paraphernalia based on evidence obtained by the police, who found evidence of methamphetamine manufacturing in the dumpster of the Choice Inn in Clovis where Defendant rented a room. Prior to trial, Defendant moved for the suppression of evidence found in the dumpster, as well as evidence obtained from the room, which was acquired by a search warrant that was based in part on the evidence recovered from the dumpster. He argued that the police's warrantless search of the garbage and subsequent immediate searches violated his constitutional right to be free of unreasonable searches and seizures. The district court granted the motion to suppress. With this opinion the Supreme Court addressed whether, pursuant to Article II, Section 10 of the New Mexico Constitution, Defendant had a reasonable expectation of privacy in garbage left out for collection in the motel dumpster. The Court of Appeals upheld the district court's ruling. The Supreme Court affirmed the Court of Appeals’ ultimate holding, but on slightly different grounds.
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