State v. Ramey, 473 P.3d 13

Officer Javier Hernandez of the Silver City Police Department testified that his routine night practice was to approach people walking and collect names/DOBs to create a database for later investigations.
At ~12:18 a.m., Hernandez drove past Ramey, made two U-turns, parked behind him with headlights on, exited, approached to within a few feet, and asked where Ramey lived and for his name and date of birth.
Ramey stopped, gave his name and DOB; Hernandez wrote it down and, while still at the scene, called dispatch to run a warrant check.
Dispatch advised Hernandez of a preexisting valid arrest warrant for driving with a revoked license; Hernandez reapproached and arrested Ramey and, in a search incident to arrest, found methamphetamine.
Ramey moved to suppress; the district court denied the motion. Ramey entered a conditional plea reserving the suppression issue and appealed.
The Court of Appeals held the initial encounter was a Fourth Amendment seizure and suppressed the evidence because attenuation did not overcome the taint of the unconstitutional seizure; it reversed and remanded to allow Ramey to withdraw his plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer's contact was a Fourth Amendment seizure	The encounter was a consensual, cordial citizen contact — not a seizure	Officer’s driving maneuvers, parking behind with headlights, approaching close at night, isolation, and asking for ID communicated authority and restrained Ramey	Seizure: a reasonable person would not feel free to leave; contact was a Fourth Amendment seizure
Whether evidence discovered after seizure must be suppressed (attenuation)	The discovery of a preexisting valid arrest warrant attenuated the illegality and made the evidence admissible	The warrant did not cure the taint because the officer’s stop was an investigatory, suspicionless tactic designed to generate a warrant check	Suppress: short temporal gap and officer’s investigatory, flagrant conduct meant attenuation did not dissipate the taint; conviction reversed and defendant may withdraw plea

Brown v. Illinois, 422 U.S. 590 (1975) (sets three-factor attenuation test: time, intervening circumstances, flagrancy of misconduct)
Utah v. Strieff, 136 S. Ct. 2056 (2016) (preexisting, untainted warrant can favor attenuation in some circumstances)
State v. Soto, 179 P.3d 1239 (N.M. Ct. App. 2008) (similar late-night stop; seizure and suppression where officers used stop to obtain ID and run warrant check)
State v. Tapia, 414 P.3d 332 (N.M. 2018) (explains exclusionary rule and attenuation analysis under New Mexico law)
State v. Monafo, 384 P.3d 134 (N.M. Ct. App. 2016) (discusses when police misconduct is "purposeful or flagrant" for attenuation analysis)