State v. Almanzar

Summary

The New Mexico Supreme Court held that a warrantless arrest for domestic violence is lawful when made within a reasonable spatial and temporal proximity to the disturbance, satisfying the statutory “at the scene” requirement. Because the arrest was lawful, the search incident to that arrest was valid and the cocaine evidence was admissible. The Court reversed the Court of Appeals and affirmed the district court’s denial of the motion to suppress.