New Mexico v. YazzieAnnotate this Case
Defendant Nathaniel Yazzie entered a conditional plea of no contest to attempt to commit negligent child abuse following the district court’s denial of his motion to suppress. Defendant moved to suppress all of the evidence gathered after Officer William Temples of the Farmington, New Mexico Police Department entered his unlocked apartment without a warrant in response to a welfare check. This entry, defendant argued, violated his Fourth Amendment rights. The State argued the entry was reasonable under the emergency assistance doctrine. By this opinion, the New Mexico Supreme Court revisited the circumstances under which an officer may make a warrantless entry into a home under the emergency assistance doctrine. Relying on cases interpreting the Fourth Amendment to the United States Constitution, the New Mexico Court held that in New Mexico v. Ryon, 108 P.3d 1032, warrantless entry is reasonable under the emergency assistance doctrine when (1) law enforcement officers “have reasonable grounds to believe that there is an emergency at hand and an immediate need for assistance for the protection of life or property;” (2) the officer's primary motivation for the search is a “strong sense of emergency” and not “to arrest a suspect or to seize evidence[;]” and (3) the officers have some reasonable basis, approximating probable cause, to connect the emergency to the area to be searched. The U.S. Supreme Court clarified the doctrine, focusing on the objective reasonableness of the officer's actions and did not include a subjective component. Applying this approach, the New Mexico Court concluded the officer's warrantless entry in this case was reasonable under the Fourth Amendment, reversing the Court of Appeals which concluded otherwise.