State v. Valdez, 2013 NMCA 016

The case concerns whether NM's ignition interlock mandate for any DWI offender violates equal protection when the impairment is due to drugs, not alcohol.
Section 66-8-102(N) requires ignition interlock installation on all vehicles driven by a DWI offender, with costs often borne by the offender.
Defendant was charged with a first-time DWI (alcohol not implicated) and had oxycodone and benzodiazepines in her system.
District court voided the interlock requirement for this defendant, holding there was no rational basis since the device detects only alcohol.
The State appealed, and the court applied rational basis review to assess the interlock statute.
The court held that the statute is rationally related to protecting public health, safety, and welfare, and reversed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the interlock statute violate equal protection when impairment is from drugs rather than alcohol?	Valdez argues interlock is overbroad and irrational as applied to drug-impaired drivers.	Castillo argues the statute furthers a legitimate public-safety goal and need not be perfectly tailored to the impairment source.	Statute passes rational basis review; constitutional.

Breen v. Carlsbad Mun. Sch., 138 N.M. 331 (N.M. 2005) (standard of review for equal protection challenges under rational basis)
State v. Druktenis, 135 N.M. 223 (N.M. 2004) (rational basis review; over-inclusiveness permissible)
State v. Anaya, 123 N.M. 14 (N.M. 1997) (bold stance on legislative discretion in DWI penalties)
Dandridge v. Williams, 397 U.S. 471 (U.S. 1970) (any state of facts may justify classification under minimal rationality)
Powell v. N.M. State Highway & Transp. Dep't, 872 P.2d 388 (Ct. App. 1994) (limits on discussing less restrictive alternatives under rational basis)
Richardson v. Carnegie Library Rest., Inc., 763 P.2d 1158 (N.M. 1988) (minimal rationality standard; broad deference to legislative classifications)