State v. Haidle, 2012 NMSC 033

Victim Tiffany Lauer-Ventura found decomposed near Los Lunas; cause blunt-force trauma to head.
Defendant interviewed Jan 30, 2009; admitted knowing Victim and paying for sex, Victim stole his tools.
November 5–6, 2009, detectives receive tips from confidential source and two concerned citizens that Defendant admitted killing Victim.
November 9, 2009, police obtained a search warrant; during execution, they recovered a bloodstained carpet piece and a bloody T-shirt from the truck.
DNA from carpet matched Victim; Defendant arrested and charged with first-degree murder and tampering with evidence.
District court suppresses some evidence but allows carpet evidence under inevitable discovery; on interlocutory appeal, the State challenges and Haidle cross-appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there constitutionally adequate probable cause for the November 9 warrant?	State contends affidavit supported probable cause.	Haidle argues affidavit lacked probable cause due to unreliable hearsay.	No; affidavit did not establish probable cause.
Did the multiple levels of hearsay satisfy the veracity and basis of knowledge requirements?	State asserts corroboration through police verification creates credibility.	Haidle contends hearsay lacks veracity and factual basis.	Hearsay failed both prongs; insufficient for probable cause.
Should inevitable discovery render the carpet evidence admissible despite lacking probable cause?	State relied on inevitable discovery to save carpet evidence.	Inevitable discovery not applicable; no independent lawful means shown.	Inevitable discovery does not justify admission.
Is there a nonhearsay basis for probable cause in the affidavit?	State cites admissions and proximity facts.	Nonhearsay facts do not amount to probable cause.	Nonhearsay allegations insufficient for probable cause.

State v. Williamson, 146 N.M. 488 (N.M. Supreme Court, 2009) (probable cause review under substantial basis standard)
State v. Nyce, 139 N.M. 647 (N.M. Supreme Court, 2006) (constitutional probable cause; reasonable inferences from affidavit)
State v. Cordova, 109 N.M. 211 (N.M. Supreme Court, 1989) (two-prong veracity and basis of knowledge for hearsay)
State v. Perea, 85 N.M. 505 (N.M. Court of Appeals, 1973) (double hearsay; veracity and basis of knowledge)
State v. Contreras, 134 N.M. 503 (N.M. Court of Appeals, 2003) (credible citizen informant; corroboration required)
State v. Jones, 96 N.M. 14 (N.M. Supreme Court, 1981) (informant details corroborated by police records)