New Mexico v. MartinezAnnotate this Case
Police Sergeant George Rascon pulled over Defendant Jennifer Martinez for failing to stop at a stop sign and, as a result, the police obtained evidence that led to Defendant’s arrest and conviction for driving while intoxicated. In a motion to suppress, Defendant argued that the video from the officer’s on board camera, or “dash-cam,” demonstrated that Defendant made a legal stop at the intersection and that the officer lacked reasonable suspicion to pull her over. At an evidentiary hearing, the officer testified that Defendant went past the stop sign before coming to a complete stop, blocking the intersection. The district court viewed the dash-cam video and concluded that the officer had reasonable suspicion to conduct the traffic stop, even though the video demonstrated that the alleged traffic violation was not as blatant as described by the officer. The Court of Appeals reversed, reasoning that the officer was not credible and that the video evidence was too ambiguous to support a finding of reasonable suspicion. After its review, the New Mexico Supreme Court held the Court of Appeals misapplied the standard of review, which required the appellate court to defer to the district court’s findings of fact if supported by substantial evidence and to view the facts in the light most favorable to the prevailing party.