2023 Farmington police shooting was constitutional, U.S. District judge says

A U.S. District Court judge ruled that the shooting of an armed Farmington man who opened his door after police officers knocked at the wrong house was constitutional.

At about midnight on April 5, 2023, Farmington police officers responding to an argument went they went to the wrong home before fatally shooting Robert Dotson when he came to the door with a gun in his hand.

In January 2024, the New Mexico Department of Justice said in a letter that it would not charge the officers involved in the shooting: Daniel Estrada, Dylan Goodluck and Waylon Wasson.

U.S. District Court Judge Matthew Garcia said the officers “reasonably believed that Dotson posed a severe risk of imminent harm,” according to an order granting partial summary judgment filed on Thursday.

The Dotson family filed a lawsuit against the Farmington Police Department alleging Estrada, Goodluck and Wasson violated the Fourth Amendment’s prohibition against unreasonable seizures by fatally shooting Dotson, the motion states. The officers’ attorneys argued they were qualified for immunity.

According to body camera video, seconds before Dotson opened the door, Farmington police officers realized they were at the wrong house.

The video showed the officers chuckle at the mistake — between 5305 and 5308 Valley View Drive. But then they backed away as Dotson came to the door, shining a blinding light on him. Dotson then opened the screen door halfway and started raising a gun at Wasson and Estrada, according to the motion. “Hey, hands up!” Wasson shouted at Dotson before officers fired, the motion states.

In the lawsuit, according to the motion, the family claimed the officers’ use of deadly force “constitutes an unreasonable and unconstitutional seizure.”

“I don’t understand how the third house on the left translates to the first house on the right, or were the big, bold, numbers not enough for you to recognize?” Robert Dotson’s wife, Kim Dotson, said during a 2023 news conference. “The incompetence of your three officers is beyond my belief, didn’t you take an oath to serve and protect our community.”

Garcia ruled, in part, that the officers acted reasonably in light of the circumstances and noted that the threat posed to the officers safety weighed in their favor.

“And though the defendant officers’ error was the reason they ended up at the Dotson’s residence, that mistake was not the factor precipitating their use of force,” the motion states. “... It was only after Dotson opened his door and began raising his firearm in the defendant officer’s direction that deadly force became necessary.

“At that moment, the defendant officers had insufficient time to deescalate the encounter without risking their safety. After all, the entirety of the interaction between the defendant officers and Dotson lasted only a few seconds.”

The attorneys for the Dotson family and city of Farmington could not be reached for comment Sunday afternoon.