New Mexico Supreme Court
State of New Mexico, Plaintiff-Petitioner/cross-Respondent v. Reymundo Carlos Garcia…
June 21, 2005138 N.M. 1
Summary
The court held that the evidence was sufficient to support Garcia's conviction for being a felon in possession because the ammunition clip matching the gun, combined with the gun's location and other incriminating circumstances, supported inferences of knowledge and control. It also held that the warrantless seizure of the gun was constitutional because the officers reasonably suspected that Garcia was armed and dangerous, creating exigent circumstances for a limited protective vehicle search. The court therefore reinstated the firearm conviction and affirmed the open-container conviction.