Idaho v. HowardAnnotate this Case
In March 2019, police officers stopped defendant-appellant Aaron Howard for a traffic violation and took him into custody after discovering an outstanding warrant for his arrest. Officers then brought in a drug-sniffing dog (“Pico”) to sniff the exterior of the car. Pico alerted to the presence of illegal drugs, and a subsequent search of the care uncovered methamphetamine, heroin and drug paraphernalia. Howard appealed the denial his motion to suppress the drug evidence, arguing the intrusion of the dog into the physical space of the car was a trespass, and therefore, an unlawful search under the common law trespassory test articulated in United States v. Jones, 565 U.S. 400 (2012). The Idaho Supreme Court agreed, reversed the denial of Howard’s motion to suppress, vacated his conviction, and remanded this case for further proceedings.