New Mexico v. Yazzie
Annotate this CaseWhile on routine patrol in San Juan County, New Mexico State Police Officer James Rempe entered the license plate number of the vehicle Defendant Joann Yazzie was driving into his patrol car’s mobile data terminal (MDT). The query returned a result indicating that the compliance status of the vehicle was “unknown.” Upon receiving the report of “unknown” compliance status (compliance with the New Mexico Mandatory Financial Responsibility Act), Officer Rempe activated his emergency lights and pulled over Defendant’s vehicle to investigate further. The “unknown” query return was the only basis for the traffic stop. Based on further information the officer acquired as a result of the stop, Defendant was arrested and charged in magistrate court with driving while under the influence of alcohol and failure to maintain insurance. Defendant filed a motion to suppress all evidence obtained during the course of the stop, arguing that the officer lacked reasonable suspicion to initiate the stop and thereby violated her right to be secure against unreasonable searches and seizures. The ultimate question this case posed for the Supreme Court's review was whether the "unknown" status could serve as the basis for the traffic stop. The Supreme Court held that an officer learning of a vehicle's "unknown" compliance status in MVD records has constitutionally reasonable suspicion to stop the vehicle and investigate further. The Court reversed the appellate court's holding to the contrary.
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