State v. Williams
149 N.M. 729
N.M.2011Background
- Defendant Williams was stopped for a traffic violation and arrested on an outstanding felony warrant.
- An officer observed furtive movements suggesting concealment of contraband or a weapon after approaching the vehicle.
- Williams was handcuffed and placed between two patrol cars; a female officer faced away while the other officer conducted the search.
- The officer conducted a pat-down and then pulled the waistband outward to reveal a plastic bag under Williams' underpants, which contained illegal substances.
- The district court denied suppression; on appeal, the Court of Appeals held the under-clothing search violated the Fourth Amendment; the NM Supreme Court granted certiorari to address the proper standard for such searches.
- The Supreme Court held that under-clothing searches, conducted incident to arrest, require a heightened standard of reasonable suspicion and applied Bell factors to determine reasonableness, ultimately affirming the search under the circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an under-clothing search incident to arrest is constitutionally reasonable. | Williams argues the search was unconstitutional. | State argues reasonable suspicion justified the invasive search. | Yes; the search was reasonable under Bell factors with reasonable suspicion. |
| What is the minimum mental standard to justify an under-clothing search? | No sufficient suspicion present. | Reasonable suspicion supports the search. | Reasonable suspicion is required for under-clothing searches. |
| Are Bell factors applicable to roadside under-clothing searches? | Bell factors do not apply beyond prison contexts. | Bell factors appropriately guide the analysis. | Bell factors apply to determine reasonableness. |
| Was the location and manner of the search proper to minimize privacy invasion? | The search exposed privacy interests on a public street. | Officers minimized exposure and conducted the search discreetly. | Location and manner were reasonable. |
Key Cases Cited
- Bell v. Wolfish, 441 U.S. 520 (1979) (establishes factors for assessing strip/search reasonableness)
- United States v. Robinson, 414 U.S. 218 (1973) (pat-down justified to ensure officer safety; limits on search scope)
- Safford Unified Sch. Dist. No. 1 v. Redding, 557 U.S. 364 (2009) (under-clothing searches require heightened justification in privacy-sensitive contexts)