NM Supreme Court: Vehicle tail lamps need not be working ‘perfectly’ to comply with state law

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SANTA FE N.M. – The New Mexico Supreme Court on Monday unanimously ruled each bulb in a tail lamp does not have to be illuminated to comply with a state law requiring a motor vehicle’s equipment to be in "good working order".

The Court’s unanimous decision stemmed from an Albuquerque man’s appeal of convictions for drunken driving and operating a vehicle with defective equipment. Defendant John Farish argued a sheriff’s deputy illegally stopped him because of a burned out tail light bulb, when the upper bulb was not working but the lower bulb was emitting light.

"This case reminds us that not all vehicles on New Mexico’s roads and highways are in perfect condition," Justice C. Shannon Bacon wrote in an opinion for the Court.

The ruling overturned a state Court of Appeals’ holding, stating all tail light bulbs must be fully functioning to satisfy the requirements that the equipment on cars, trucks, trailers and other vehicles be in "good working order and adjustment."

The Supreme Court concluded that as long as a vehicle’s tail lamp complies with specific equipment requirements in state laws, then it meets the more general requirement to be in "good working order" – even if there is a burned out bulb on a tail lamp with multiple bulbs. The requirements include that it emits enough light to be visible from at least 500 feet.

The Legislature established standards for motor vehicle equipment such as lights and brakes for "what it deems necessary to render a vehicle safe, but does not in these sections require that it work ‘at 100%’ or ‘perfectly’ as the Court of Appeals concluded," the justices wrote.

"Accordingly, ‘good working order’ does not require equipment to function 100% perfectly if it is suitable or functioning for its intended use," the Court held.

The justices ordered Farish’s case back to Second Judicial District Court to resolve in accordance with the Supreme Court’s interpretation of state law. Farish was convicted in the Bernalillo County Metropolitan Court. He appealed to the district court and then the Court of Appeals.

Farish contended that his convictions should be reversed because the sheriff’s deputy lacked reasonable suspicion of a traffic violation to justify stopping his vehicle, which subsequently led to the DWI charge.

The Court of Appeals, in a split decision, found insufficient evidence for the convictions based on a law governing the visibility of tail lamps or another section that prohibits driving a vehicle with equipment in such an unsafe condition that it endangers other motorists. However, in upholding Farish’s convictions, the Court of Appeals determined there was a basis for the traffic stop because the faulty tail light bulb violated requirements for a vehicle’s equipment to be in good working condition.