State v. Goodman, 10 N.M. 815

Background

At ~2:00 a.m. in downtown Albuquerque, Officer Landavazo stopped behind Goodman at a red light; intersection had three lanes (northbound, southbound, shared left-turn).
When the light turned green, Goodman did not move immediately; 5–15 seconds elapsed before he proceeded.
Officer Landavazo activated his emergency lights the moment Goodman began to move and stopped him solely for violating a City Ordinance prohibiting obstructing the free use of a public way.
Goodman moved to suppress evidence arguing the stop lacked reasonable suspicion; metropolitan court denied the motion, Goodman pled guilty reserving appeal, and the district court affirmed.
The Court of Appeals reviewed whether a 5–15 second delay after a green light can, as a matter of law, constitute an obstruction under the ordinance and whether the officer’s stop was therefore based on a mistake of law.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a short (5–15 sec) delay after a light turns green can violate the Albuquerque ordinance prohibiting obstruction of a public way	Any delay that impedes forward progress in a lane obstructs traffic and violates the ordinance	A brief, transitory delay that does not obstruct the roadway or prevent others from using the public way is not an obstruction; ordinance requires meaningful interference	A mere 5–15 second delay after a red light turns green, standing alone, does not as a matter of law "obstruct the free use" of the public way; not the harm the ordinance targets
Whether the officer had reasonable suspicion to stop Goodman based solely on that delay	The observed delay provided reasonable suspicion that the ordinance was being violated	The officer’s belief was an unreasonable mistake of law; the delay was de minimis and did not give rise to reasonable suspicion	The stop was not justified at its inception; officer operated under an unreasonable mistake of law and lacked reasonable suspicion
Whether the Ordinance requires obstruction of all lanes or any meaningful interference to constitute an offense	Any spatial or temporal interference with forward progress qualifies as obstruction	Ordinance should be read to require meaningful interference with free use of the public way (not simply one vehicle momentarily delayed)	Court rejects bright-line requirement that all lanes be blocked but requires more than a momentary, subjective delay; single-lane obstruction is possible in principle but not established here
Remedy for an investigatory stop based on insufficient reasonable suspicion	Evidence obtained from stop may be used if officer acted in good faith	Evidence should be suppressed where stop lacked reasonable suspicion	Suppress evidence obtained from the improper stop; reverse conviction and remand for proceedings consistent with opinion

Key Cases Cited

State v. Jason L., 129 N.M. 119, 2 P.3d 856 (describing reasonable suspicion standard for investigatory stops)
State v. Leyva, 149 N.M. 435, 250 P.3d 861 (appellate review standards for suppression rulings)
State v. Duran, 138 N.M. 414, 120 P.3d 836 (applying reasonable suspicion analysis to traffic stops)
May v. Baklini, 85 N.M. 150, 509 P.2d 1345 (obstruction can occur in a single lane)
State v. Hubble, 146 N.M. 70, 206 P.3d 579 (objective test for whether circumstances justify an investigatory stop)
State v. Almanzar, 316 P.3d 183 (standards for mixed questions of law and fact on suppression issues)