NM: Citizen informant’s call about erratic driving was RS for stop when the vehicle was found

Citizen informant’s call to the police about erratic driving was reasonable suspicion for defendant’s stop when the car was found. State v. Tidey, 2011-NMCA-068, 2017 N.M. App. LEXIS 103 (Oct. 17, 2017).

The stop was justified by a lane change violation. Reasonable suspicion comes from: “(1) the Honda Odyssey minivan had dark window tint, which is common on vehicles used to transport illegal contraband; (2) the van was travelling on Interstate 80, which is a known major drug corridor; (3) two other SHIELD members conducted stops on Honda Odyssey vans that contained a hidden trap in the rear bumper; (4) Meran said the van belonged to his friend Angel, but he did not know Angel’s last name; (5) the van was registered in Philadelphia, Pennsylvania, to Angel Rameu, not Meran, who possessed a New York driver’s license; (6) Philadelphia and New York are major source and consumption areas for drugs; (7) there was a single key in the ignition, which often signifies a third-party vehicle used by individuals who smuggle contraband; (8) there was an energy drink in the van, which often indicates the occupants are attempting to travel a long distance in a short period of time; and (9) there were air fresheners in the van, which are often used to mask the odor of narcotics.” United States v. Meran, 2017 U.S. Dist. LEXIS 174849 (W.D. Pa. Oct. 23, 2017).*

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