NM: Consent to look at one receipt during a stop didn’t justify looking at any others

Two stops of defendant towing a van a couple of minutes apart were separately justified. The second stop was based on the owner of the van saying that defendant took it from him, but that was only to a second officer on the scene, not the one who stopped defendant. After defendant pulled away, the second stop occurred, and it was based on new facts. Defendant consented to the officer looking at one receipt. Looking at the whole receipt book, however, exceeded the scope of consent, and that required reversal. State v. Monafo, 2016 N.M. App. LEXIS 75 (July 28, 2016).

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