Idaho v. Dorff
Annotate this CaseKirby Dorff appealed the denial of his motion to suppress evidence obtained after a police drug-sniffing dog jumped onto the exterior surface of his vehicle. Dorff argued the dog’s contact with his vehicle was a trespass, and therefore, an unlawful “search” under the common law trespassory test as articulated in United States v. Jones, 565 U.S. 400 (2012), applied in Idaho by Idaho v. Howard, 496 P.3d 865 (2021) and Idaho v. Randall, 496 P.3d 844 (2021). The Idaho Supreme Court found the drug dog intermeddled with Dorff’s vehicle when it jumped onto the driver side door and window, planted two of its paws, and sniffed the vehicle’s upper seams. Accordingly, law enforcement conducted a warrantless and unlawful “search” of Dorff’s vehicle by way of its drug dog. The denial of Dorff’s motion to suppress was reversed, his conviction was vacated, and this case was remanded to the district court for further proceedings.
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