New Mexico Supreme Court

State v. Paananen

September 10, 20152015 NMSC 31

Summary

The New Mexico Supreme Court held that the warrantless arrest of Ernest Paananen for shoplifting was reasonable under both the federal Fourth Amendment and Article II, Section 10 of the New Mexico Constitution because exigent circumstances existed, and that the subsequent search incident to that arrest was lawful. Accordingly, the Court reversed the Court of Appeals and remanded for further proceedings.