CLOVIS, N.M. (KAMR/KCIT) — The New Mexico Supreme Court announced on Monday that it overturned a Clovis woman’s drug possession conviction because a warrantless search of her purse by police violated her constitutional protections against unreasonable searches.

The Court ruled unanimously that the case be sent back to the district court in Curry County for the Clovis woman’s felony conviction and sentence for possession of a controlled substance to be vacated. In the published opinion, the Court reminded prosecutors and district courts of “their obligations to make a sufficient record when considering the propriety of warrantless searches and when taking judicial notice” of facts in a case.

The ruling overturns a 2015 conviction in Curry County, for which the Clovis woman received a suspended sentence of 18 months of probation, and affirmed the decision of the state Court of Appeals that drug evidence used in her case was inadmissible.

According to details from the court office, the Clovis police originally arrested the woman on a warrant for criminal trespass. After handcuffing her, police searched a purse that was hanging on her shoulder and “found a small knife and two flashlights,” one of which contained a small baggie of methamphetamine. After the warrantless search, the woman was charged with possession of a controlled substance.

The Court noted that under the law, warrantless searches are presumed to be unreasonable and the state must prove they are reasonable under the individual circumstances. While appealing her conviction, the Clovis woman argued that the state failed to prove that the warrantless search of her purse was reasonable, and the Supreme Court agreed.

“In this case, we hold that the State failed to meet its burden to demonstrate the reasonableness of the officers’ search of Defendant’s purse because the State failed to put forth any evidence that the purse was within the Defendant’s immediate control such that Defendant presented a danger of gaining possession of a weapon or was in a position to destroy evidence of her arrest,” said the Court’s opinion, “Despite the State’s arguments to the contrary, there is limited evidence in the record as to the location of the purse at the time of arrest, whether it was secured, its distance from Defendant, how she was handcuffed such that she would be able to access the purse, and whether and why the officers had concerns for their own safety or the destruction of evidence.”

The district court previously ruled that the search was proper and that the drugs would have been lawfully found during booking, when the Clovis woman’s purse was inventoried by police, making the drug evidence admissible at trial because of the legal principle known as “inevitable discovery.” However, the Supreme Court decided that the district court did not properly take judicial notice of the jail’s inventory process and failed to establish on the record how that process would be common knowledge or settled.

Because of that, the Court said, “there is no evidence in the record to establish the jail’s inventory process and whether it would have inevitably discovered the methamphetamine in Defendant’s purse. Further, there is no evidence that the jail’s procedures would have included a search of the flashlights found in Defendant’s purse during an inventory search.”

The full decision, noted the Court, can be found on the New Mexico Compilation Commission’s website.

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