State v. Goodman
2017 NMCA 10
| N.M. Ct. App. | 2016Background
- At ~2:00 a.m. Officer Landavazo stopped behind Goodman at a red light on a three-lane downtown street (southbound, northbound, and a center left-turn lane).
- When the light turned green, Goodman did not move for approximately 5–15 seconds; when he began moving the officer immediately activated emergency lights and stopped him.
- The officer’s sole basis for the stop was a City of Albuquerque ordinance prohibiting obstructing the free use of a public way; Goodman was cited for obstructing traffic.
- Goodman moved to suppress evidence from the stop for lack of reasonable suspicion; metropolitan court and district court denied suppression; Goodman reserved right to appeal.
- The Court of Appeals reviewed whether a short (5–15 second) delay in proceeding on a green light can, as a matter of law, support reasonable suspicion of violating the ordinance and concluded it cannot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a 5–15 second delay after a red light turns green can constitute "obstructing the free use" of a public way under the Albuquerque ordinance | Any delay that impedes progress in a travel lane can be an obstruction; no minimum temporal threshold is required | A transient delay after a lawful stop does not obstruct the public way; the ordinance should not be applied to brief, innocuous delays | A brief delay of mere seconds after a red light is not, as a matter of law, an obstruction; such a stop lacks reasonable suspicion |
| Whether the officer acted under a reasonable mistake of law in initiating the stop | The officer reasonably interpreted the ordinance to prohibit the delay and therefore had reasonable suspicion | The officer’s interpretation was subjective and undefined, making the stop an unreasonable mistake of law | Officer’s view was an unreasonable/ad hoc application of the ordinance; courts are not bound by such mistakes of law |
| Whether evidence obtained from the stop should be suppressed | Stop was lawful; evidence admissible | Stop lacked reasonable suspicion and thus evidence should be suppressed | Suppress evidence obtained from an investigatory stop initiated without reasonable suspicion |
| Whether the ordinance requires obstruction of the entire public way to be violated | (State did not press an “entire width” requirement) | Defendant argued the ordinance must be read to require obstruction of the entire public way to avoid arbitrary enforcement | Court rejected need to show entire width obstructed but held that transient, seconds-long delays are not the kind of obstruction the ordinance reaches |
Key Cases Cited
- Harris Books, Inc. v. City of Santa Fe, 647 P.2d 868 (court requires ordinances give fair notice of prohibited conduct)
- State v. Jacquez, 222 P.3d 685 (ordinance invalid where it fails to give minimum guidelines for officers and invites ad hoc enforcement)
- State v. Almanzar, 316 P.3d 183 (standard of review for denial of suppression; mixed question of law and fact)
- State v. Leyva, 250 P.3d 861 (reasonable suspicion standard for investigatory/traffic stops)
- May v. Baklini, 509 P.2d 1345 (obstruction can occur in a single lane; relevant background on ordinance language)
- State v. Hall, 294 P.3d 1235 (interpretive guide: examine the object/wrong the ordinance seeks to address)