State v. Hernandez, 364 P.3d 313

Undercover agents made multiple heroin buys in July–August 2012 involving middlemen (Mendenhall, Hall, Malchete) and two locations: Space 104 (Oñate Greens Trailer Park) and a Merriweather Street house.
On July 3 and July 23 agents observed brief (2–10 minute) entries into Space 104 or the Merriweather house; drugs were later turned over to agents by the middlemen after those entries.
On August 10 agents observed a gold/tan SUV at the Merriweather house during a buy and recorded its license plate (SUV later linked to the house resident).
On August 23 agents surveilled Space 104, saw the same gold SUV stop, drop off two passengers, park at Space 104 for ~3–5 minutes while remaining occupants made contact with someone in Space 104, then pick up the dropped passengers and leave.
Agents directed a marked unit to stop the SUV about a block away; after the stop a female passenger identified Hernandez as the person with heroin and Hernandez voluntarily handed an agent a package of heroin.
Hernandez moved to suppress the seized heroin and statements, arguing the stop lacked reasonable suspicion; the district court denied suppression and the Court of Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hernandez)	Held
Whether the investigatory stop of the SUV was supported by reasonable suspicion	Totality of undercover buys, SUV observed at Merriweather during buy, SUV’s brief stops and passenger drop/pick pattern at Space 104 matched drug-trafficking pattern—these facts gave officers particularized, objective basis to suspect ongoing drug activity	The SUV’s presence at a suspected drug house and agents’ inferences were speculative/hunches; buys were uncontrolled and based on unreliable suspects; presence alone is insufficient for reasonable suspicion (citing Neal)	Affirmed: stop was supported by reasonable suspicion under totality of circumstances; deference given to agents’ training and inferences

United States v. Arvizu, 534 U.S. 266 (recognizing totality-of-circumstances and deference to officers’ inferences for reasonable suspicion)
Alabama v. White, 496 U.S. 325 (reasonable suspicion can arise from less reliable information than probable cause)
United States v. Cortez, 449 U.S. 411 (reasonable suspicion based on common-sense inferences and probabilities)
State v. Neal, 142 N.M. 176, 164 P.3d 57 (presence at a known drug house and association not alone sufficient for reasonable suspicion)
United States v. Askew, 403 F.3d 496 (pattern of behavior viewed collectively by experienced agents can justify an investigatory stop)
United States v. Harley, 682 F.2d 398 (brief stop at suspected drug sale location can support reasonable suspicion)
United States v. Gomez, 633 F.2d 999 (observations of repeat patterns in high narcotics area support reasonable suspicion)