NM: Name on an older warrant list wasn’t individualized suspicion when stop occurred

The officer believed defendant’s name was on an old warrant list they get from the magistrates once every week or two. The age of the list denied individualized suspicion. It wasn’t checked before the stop (even though it turned out there was still a warrant). State v. Robles, 2026 N.M. App. LEXIS 3 (Jan. 15, 2026):

Here, the officer did not have the same individualized suspicion of Defendant. The officer did not check the active warrant list on the day of the traffic stop, and the officer did not observe Defendant commit any traffic infractions nor run Defendant’s license plates prior to conducting the stop. The officer’s sole basis for stopping Defendant was his inarticulable belief that Defendant had an active arrest warrant. This is insufficient to establish the particularized suspicion required at the inception of a traffic stop. See Jason L., 2000-NMSC-018, ¶ 22 (requiring “[i]ndividualized, particularized suspicion [a]s a prerequisite to a finding of reasonable suspicion”).