analysis in Lara to this case because, in Lara, the officers conducted the protective sweep after finding and arresting the defendant inside the house while investigating a violent crime that “had just occurred” inside of the house. Id. at 511, 514, 797 P.2d at 300, 303. {26} In contrast to the facts in Lara, the agents here were not investigating a violent crime that “had just occurred” inside the house or even within New Mexico. Instead, they were merely serving an arrest warrant for a crime that had taken place in Mississippi at some unspecified point in the past. In any event, Lara does not compel a conclusion that a protective sweep is justified based on the serious nature of the crime being investigated. See, e.g., United States v. Hogan, 38 F.3d 1148, 1149-50 (10th Cir. 1994) (<HOLDING>). {27} The State also relies on a number of
holding that the protective sweep incident to the defendants arrest in front of his house on suspicion of murder was not justified because the evidence that an accomplice was involved in the murder did not equate to evidence that someone would be hiding out in the defendants house a month after the crime occurred and at the time of the arrest the officers were not chasing the defendant from a crime scene holding that the officers were justified in conducting a protective sweep incident to the defendants arrest on outstanding warrants because the officers had information that the defendant was suspected of running a methamphetamine operation on the premises other people were living there and assisting the defendant and at the time the sweep began the defendant had not yet been located holding that protective sweep was justified incident to arrest outside residence where officers had reasonable suspicion that dangerous individuals were in apartment recognizing that the justification for a protective sweep of even a few minutes would be questionable in light of the officers concession that after arresting the defendant in front of his house the officer could have just put the defendant in the car and driven away holding that officers were not justified in conducting a protective sweep incident to the defendants arrest despite the defendants alleged involvement with narcotics and possession of weapons because the defendant did not resist and there was no noise or other evidence suggesting anyone else was present in the house