Idaho v. Riendeau
Annotate this CaseJesse Riendeau was arrested for driving while under the influence of alcohol by a Coeur d’Alene police officer. The officer transported him to the jail, where the officer asked that Riendeau submit to a breath test for alcohol concentration. He did, and the two tests showed an alcohol concentration in excess of the statutory limit. Riendeau was charged with driving while under the influence of alcohol. Riendeau filed a motion to suppress the results of the breath test on the ground that the breath test constituted a search and that his consent to that search was obtained unconstitutionally by the threat of a civil penalty of $250 and a one-year suspension of his driving privileges and by the false statement that he was required by law to submit to the breath test. On May 6, 2013, he filed a motion in limine seeking to exclude from evidence the result of the breath test because the State Police’s change of the word “must” to “should” in its standard operating procedures resulted in there being no standards to ensure the reliability of the test results. After an evidentiary hearing, briefing, and argument, the magistrate court denied both motions. Riendeau then pled guilty to driving under the influence of alcohol pursuant to a conditional plea agreement which provided that he would enter a conditional plea of guilty, that he could appeal the orders denying his motions, and that if he prevailed on appeal he could withdraw his guilty plea. The court accepted the plea agreement and sentenced Riendeau. He then appealed to the district court, and it affirmed the magistrate court. He then appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed.
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