“Accordingly, based upon our application of the Brown factors in a circumstance markedly similar to Strieff, we conclude that Defendant’s arrest warrant was an intervening cause that broke the causal chain between Officer Townsend’s unlawful detention of Defendant and the seizure, of evidence from Defendant after his arrest.” State v. Edwards, 2019 N.M. App. LEXIS 107 (Aug. 22, 2019).
The district court erred in excluding statistical evidence offered by plaintiff in an attempt to show that one officer selectively enforced laws against Black drivers. Remanded for more development of the record. Johnson v. Holmes, 2019 U.S. App. LEXIS 25566 (4th Cir. Aug. 26, 2019).*