State v. Martinez, 410 P.3d 186

Bloomfield police Sergeant George Rascon stopped Jennifer Martinez after observing her at a four-way stop intersection; dash-cam video and the officer’s testimony were admitted at the suppression hearing.
Officer testified Martinez approached at a high rate of speed, went past the stop sign, and braked such that her car protruded into the intersection, blocking a lane.
Martinez moved to suppress, arguing the dash-cam showed she made a legal stop and the officer lacked reasonable suspicion; the magistrate denied suppression and she entered a conditional guilty plea reserving the suppression issue.
On de novo review, the district court viewed the dash-cam, heard the officer, found the truth “somewhere in between,” and denied the motion, concluding the officer had reasonable suspicion.
The Court of Appeals reversed, concluding the officer was not credible and that the dash-cam alone was too ambiguous to support reasonable suspicion.
The Supreme Court granted certiorari and reversed the Court of Appeals, holding appellate review must defer to district court factual findings supported by substantial evidence and view facts in the light most favorable to the prevailing party.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court’s factual findings on a suppression motion should be reviewed de novo or with deference	State: appellate courts must defer to district court findings if supported by substantial evidence and view facts in favor of prevailing party	Martinez: dash-cam video is documentary evidence that permits independent appellate factfinding; video shows no violation	Held: appellate courts must defer to district court factfindings supported by substantial evidence and review legal reasonableness de novo
Whether dash-cam video alone disproves reasonable suspicion for the stop	State: video plus officer testimony, when viewed in totality and with deference to district court, supports reasonable suspicion	Martinez: objective video contradicts officer’s testimony so video should control and suppress evidence	Held: video was ambiguous and did not incontrovertibly contradict the officer; district court permissibly credited portions of testimony and found reasonable suspicion

State v. Jason L., 129 N.M. 119, 2 P.3d 856 (N.M. 2000) (appellate courts must indulge reasonable inferences supporting district court findings)
State v. Yazzie, 376 P.3d 858 (N.M. 2016) (mixed question: defer to factual findings, review legal application de novo)
State v. Ketelson, 257 P.3d 957 (N.M. 2011) (suppression review framework)
State v. Urioste, 52 P.3d 964 (N.M. 2002) (reasonable suspicion requires specific articulable facts)
United States v. Arvizu, 534 U.S. 266 (2002) (totality of circumstances; avoid divide-and-conquer analysis)
State v. Gonzales, 257 P.3d 894 (N.M. 2011) (officer’s training and inferences are relevant to reasonable suspicion)