New Mexico Supreme Court

State v. Antonio T.

June 22, 20158 N.M. Ct. App. 130

Summary

The New Mexico Supreme Court reversed the district court and Court of Appeals, holding that a school official's questioning of a minor in the presence of a law‑enforcement officer constitutes an investigatory detention that triggers the statutory right to be warned of the right to remain silent; because the State failed to prove a knowing, intelligent, and voluntary waiver, the minor’s statements were inadmissible.