State v. Almanzar, 2014 NMSC 001

Defendant Almanzar allegedly battered Victim at the New Mexico State Fairgrounds parking lot; Victim called 911 and later identified Almanzar.
Almanzar left the scene and was arrested across the street at a Circle K; officers then transported him to Walgreens to locate Victim.
A pat-down incident to arrest yielded a golf-ball-sized mass of cocaine which was later charged as trafficking.
Defendant moved to suppress the cocaine as the arrest violated the “at the scene” requirement of §31-1-7(A).
The district court denied suppression; the Court of Appeals reversed, holding the arrest was unlawful under the literal reading of “at the scene.”
State sought Supreme Court review to determine whether the warrantless arrest was lawful under §31-1-7(A).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ‘at the scene’ in §31-1-7(A) allows a warrantless arrest near, but not at, the exact location of the disturbance	State contends the arrest was within minutes and across the street, satisfying proximity.	Almanzar argues the arrest must occur at the precise scene, i.e., the exact location of the disturbance.	Arrest was lawful; proximity within minutes satisfies ‘at the scene’ standard.
What legislative intent underpins §31-1-7(A) when assessing ‘at the scene’	Broad interpretation aligns with protecting victims and rapid response to domestic violence.	Literal interpretation limits officer authority to the precise location of the incident.	Legislative intent favors a reasonable proximity reading to protect victims while balancing rights.
Does the lawful arrest under §31-1-7(A) validate the search incident to arrest for cocaine	If arrest is lawful, the search incident is a valid exception to the warrant requirement.	If arrest is invalid, the cocaine should be suppressed as fruits of an unlawful arrest.	Because arrest was lawful, the search incident to arrest was valid.

State v. Williams, 149 N.M. 729, 255 P.3d 307 (N.M. 2011) (warrantless searches and limitations on police discretion)
Moongate Water Co. v. City of Las Cruces, 302 P.3d 405 (N.M. 2013) (statutory interpretation and public utility regulation context)
State v. Hall, 294 P.3d 1235 (N.M. 2013) (statutory interpretation framework for de novo review)
State v. Rowell, 188 P.3d 95 (N.M. 2008) (classic warrant exceptions and searches incident to arrest)
City of Las Cruces v. Sanchez, 210 P.3d 212 (N.M. 2009) (misdemeanor arrest in presence rule and domestic disturbance)
Baker v. Hedstrom, 309 P.3d 1047 (N.M. 2013) (interpretation of statutory provisions in pari materia)