State v. Crane
254 P.3d 117
N.M. Ct. App.2011Background
- Police received an anonymous tip of a strong chemical odor from Room 316 at the Choice Inn, suspecting meth manufacture.
- Agent Rains observed Kidd discard an open box at the motel dumpster and later found two sealed bags in the dumpster with a chemical odor.
- Without obtaining a warrant, the agents opened and searched the two sealed bags and found meth-related items.
- Agent Wright obtained a search warrant for Room 316 and related vehicles; more paraphernalia was found, and Defendant was charged with trafficking methamphetamine and possession of drug paraphernalia.
- Defendant moved to suppress the dumpster evidence under Granville; the district court suppressed the sealed-bag items and the State appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Defendant had a reasonable privacy expectation in motel-garbage under Article II, Section 10 | State argues no reasonable expectation in motel garbage. | Crane argues there is a reasonable expectation similar to Granville. | Defendant has a reasonable privacy expectation; suppression affirmed. |
| Granville extends to motel dumpsters to limit warrantless searches | State contends Granville does not apply to motel dumpsters. | Crane contends Granville's privacy protection extends to motel-dumpster context. | Granville extended; privacy protects garbage in motel dumpster; warrantless search unreasonable. |
| Which framework governs, Katz two-prong or reasonableness under NM Constitution | State relies on generalized privacy analysis; argues for broader application of Katz. | Crane supports a reasonableness-focused NM standard (Hempele approach) and not subjective prong. | Use reasonableness standard under Article II, Section 10; subjective expectation not required. |
Key Cases Cited
- Granville v. State, 140 N.M. 345 (2006-NMCA-098) (recognizes privacy in garbage left for collection under NM Constitution)
- State v. Zamora, 110 P.3d 517 (2005-NMCA-039) (extends motel guest privacy in a multi-unit setting)
- Hempele, 576 A.2d 802 (N.J. 1990) (rejected strict Katz two-prong; NM adopts reasonable-expectation approach)
- Stoner v. California, 376 U.S. 483 (1964) (hotel guest privacy protection akin to home occupancy)
- California v. Greenwood, 486 U.S. 35 (1988) (public-access theory for garbage not adopted by NM in Granville)
- State v. Morris, 680 A.2d 90 (1996) (privacy in garbage in multi-unit dwellings; supports Granville reasoning)