New Mexico Supreme Court
State v. Yazzie
January 24, 2019
Summary
The New Mexico Supreme Court held that Officer Temples’ warrantless entry and subsequent safety sweep of the defendant’s home were reasonable under both the Fourth Amendment emergency assistance doctrine and Article II, Section 10 of the state constitution. The Court applied a two‑part objective test for the federal analysis and the full three‑part Ryon test for the state‑constitutional analysis, affirming the district court’s denial of the motion to suppress and reversing the Court of Appeals. The case was remanded for resolution of any remaining issues.