State v. Ayon (Published Opinion)
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This case arises from an incident in which Ricky Anthony Ayon was stopped by police while walking on the street. The police officer, recognizing Ayon from past encounters and knowing he had a warrant, immediately handcuffed Ayon and later discovered a small bag of a substance that tested positive for opiates. During a preliminary hearing, Ayon successfully argued that the police officer lacked reasonable suspicion to stop him, leading the district court to refuse to bind Ayon over for trial on a heroin possession charge. The Court of Appeals reversed this decision, leading to this appeal.
The Supreme Court of the State of New Mexico held that a district court judge presiding over a preliminary hearing does not have the authority to decide whether evidence was obtained from an unconstitutional search or seizure. The Court remanded the case for proceedings consistent with this opinion. The Court reasoned that even though preliminary hearings and grand jury proceedings have different procedures and afford different rights to the defendant, they share a common goal of providing a neutral evaluation of whether the state has demonstrated probable cause to prosecute a serious crime. Additionally, the Court noted that allowing suppression of evidence at the preliminary hearing stage would be largely duplicative and not necessary for effective screening, as a motion to suppress evidence could still be utilized to gain a pretrial ruling excluding the evidence and precluding a trial. The Court also held that the New Mexico Constitution does not provide the right at a preliminary hearing to exclude evidence obtained from an unconstitutional search or seizure.
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