State v. James, 33,312 33,701

Defendant was charged in magistrate court with aggravated DWI (third), driving with a suspended/revoked license, failure to maintain lane, and failure to carry proof of financial responsibility; he entered a conditional plea reserving the right to appeal suppression and six-month-rule rulings.
Deputy Benally, who had multiple prior encounters and radio information indicating Defendant’s license was suspended (including an earlier stop and a recent radio report of an arrest for DWI and suspended license), followed and stopped Defendant after observing possible lane and seatbelt violations.
After the stop Deputy Benally confirmed the license suspension, detected signs of intoxication, administered field sobriety tests, and arrested Defendant.
The district court (on de novo review) granted Defendant’s motion to suppress, concluding Deputy Benally lacked reasonable suspicion and that the traffic infractions were pretextual; it denied Defendant’s motion to dismiss under the magistrate-court six-month rule.
The Court of Appeals reversed the suppression ruling (holding reasonable suspicion existed based on prior encounters and recent radio information) and affirmed denial of dismissal under Rule 6-506 (concluding the six-month clock restarted when a bench warrant issued and Defendant surrendered).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop violated the Fourth Amendment / N.M. Const. art. II, § 10 because Deputy Benally lacked reasonable suspicion to stop Defendant for driving with a suspended/revoked license	The State: prior personal encounters plus a recent radio report that Defendant had been arrested for DWI and a suspended license provided specific, articulable facts yielding reasonable suspicion to stop	James: the officer’s belief was speculative and stale; officer should have confirmed suspension by radio before effecting a stop; subsequent observed minor traffic violations were pretextual	Reversed suppression: reasonable suspicion existed based on prior stops and contemporaneous radio information; stop lawful; no need to decide pretext issue
Whether the magistrate-court proceedings violated Rule 6-506(B) (the six‑month rule) requiring dismissal where trial did not commence within 182 days	The State: bench warrant issued when Defendant missed the May 9 trial and Defendant surrendered; Rule 6-506(B)(5) restarts the 182‑day clock on arrest/surrender so no dismissal was required	James: trial deadline passed May 6; the State’s extension motion was late and exceptional circumstances not shown, so the case should have been dismissed with prejudice	Affirmed denial of dismissal: bench warrant issuance and Defendant’s surrender restarted the six‑month clock; no six‑month violation

United States v. Sandridge, 385 F.3d 1032 (6th Cir. 2004) (officer’s prior information that driver lacked a valid license supported reasonable suspicion for a later stop)
State v. Candelaria, 245 P.3d 69 (N.M. Ct. App. 2011) (reasonable suspicion where officer learned via plate check/MVD records that owner’s license was suspended)
State v. Yazzie, 376 P.3d 858 (N.M. 2016) (applying same reasonable-suspicion analysis under federal and New Mexico constitutions; officer may rely on MVD records)
State v. Halvorson, 997 P.2d 751 (Mont. 2000) (prior knowledge of a driver’s earlier license revocation supported stop months later)
State v. Duesterhoeft, 311 N.W.2d 866 (Minn. 1981) (officer’s knowledge a month earlier that driver’s license was suspended supported reasonable suspicion)
State v. Dorais, 370 P.3d 771 (N.M. Ct. App. 2016) (six‑month clock restarts when defendant is arrested for failure to appear; bench warrant arrest triggers Rule 6‑506(B)(5))