Idaho v. MaximAnnotate this Case
Andrew Maxim was charged with felony possession of a controlled substance. He appealed the district court’s denial of his motion to suppress drug evidence found on his person after police searched the home he was living in without a warrant. The district court found that the exclusionary rule need not apply under the circumstances because the police would have inevitably discovered the heroin despite any alleged illegality. The dispositive issues on appeal were whether a probationer could object to a search of his home or person when he waived his Fourth Amendment rights as a condition of probation and whether the district court erred in its inevitable-discovery analysis. After review, the Idaho Supreme Court reversed, holding that a Fourth Amendment waiver which is unknown to an officer at the time of a Fourth Amendment violation could not be relied on to assert that the search was reasonable. The Supreme Court also determined the district court misapplied the inevitable discovery doctrine by engaging in a speculative analysis that did not rely on an investigative path set in motion prior to or independent of the unlawful police activity. The district court’s judgment of conviction was vacated, the denial of Maxim’s motion to suppress was reversed, and the matter remanded for further proceedings.