State v. Olson, 258 P.3d 1140

Defendant Gunnar Olson was stopped after his vehicle entered and exited an alley behind a convenience store, prompting a traffic stop for a significantly expired temporary tag.
Officer Economidy observed the passenger, known to be a prostitute, and suspected prostitution-related activity based on her identity and appearance.
Defendant exited the vehicle at the officer’s request; the officer conducted a safety check of a fanny pack he believed could contain weapons.
The officer examined the fanny pack with Defendant’s consent and found two glass crack pipes and one metal crack pipe, leading to admission of cocaine use.
A warrantless search yielded cocaine from Defendant’s front pocket; Defendant moved to suppress all evidence on Fourth Amendment and Article II, Section 10 grounds, which the district court denied.
Defendant pleaded no contest to possession of cocaine while preserving the right to appeal the suppression ruling; the appellate court reversed, suppressing the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was unreasonably extended.	Olson argues the stop extended beyond its lawful purpose.	Olson contends move to interrogate about prostitution was not related to the stop.	Yes, unlawful extension under Article II, Section 10.
Whether questioning about prostitution was reasonably related to the stop.	State argues ongoing prostitution inquiry was related.	Olson argues lack of independent suspicion; safety concerns insufficient.	Unrelated questions lack independent suspicion; unlawful under Article II, Section 10.
Whether consent to search purged the Fourth Amendment violation.	Consent cleanses taint of initial unlawful detention.	Consent was tainted by unlawful detention.	Consent did not purge taint; suppression required.

State v. Leyva, 2011-NMSC-009 (New Mexico Supreme Court 2011) (two-part test for traffic-stop reasonableness; Article II, Section 10 requires related questions unless independent justification)
State v. Vandenberg, 2003-NMSC-030 (New Mexico Supreme Court 2003) (established initial stop justified by traffic violation; totality of circumstances review)
State v. Funderburg, 2008-NMSC-026 (New Mexico Supreme Court 2008) (reasonable suspicion required for extensions beyond stop; totality-based analysis)
State v. Sewell, 2009-NMSC-033 (New Mexico Supreme Court 2009) (reasonableness of stop assessed under evolving circumstances; de minimis extensions allowed)
State v. Duran, 2005-NMSC-034 (New Mexico Supreme Court 2005) (establishes framework for Fourth Amendment stop analysis in New Mexico)