Campos v. State

OPINION

RANSOM, Chief Justice.

Frank Martin Campos was convicted of illegal possession of heroin under NMSA 1978, Section 30-31-23(B)(4) (Repl. Pamp.1989). Campos appealed his conviction to the Court of Appeals, which affirmed. State v. Campos, 113 N.M. 421, 827 P.2d 136 (Ct.App.1991). This Court issued its writ of certiorari to address whether, under Article II, Section 10 of the New Mexico Constitution, the propriety of warrantless arrests in public places is dependent on exigent circumstances. For a warrantless arrest to be reasonable it must be based upon both probable cause and sufficient…