Idaho v. Warren
Annotate this CaseThe State appealed a district court’s order granting Jennifer Warren’s (“Jennifer”) motion to suppress evidence. Boise Police Department Officer Matthew Lane stopped a GMC Yukon for a canceled and expired registration. The vehicle was driven by Steven Warren (“Steven”), and Jennifer was in the passenger seat. Steven told officers that Jennifer was his wife. Lane ran the identification information supplied by both parties, and the data system alerted there was a civil protection order and a criminal no-contact order in place preventing Steven from having contact with Jennifer. At this point, the officer abandoned the original purpose of the traffic stop in order to investigate whether Steven was in violation of either order by being with Jennifer in the car. To separate Jennifer from Steven, a second officer, Andrew Morlock, asked Jennifer to step out of the vehicle. Morlock asked Jennifer about some bulges in her pockets, and she pulled out a lighter, some money, and two syringes wrapped in tissue. Lane ran his drug-detection dog around the vehicle, and the dog alerted. A search of the car turned up a suspected marijuana joint and a tin holding small containers of a waxy substance, one of which later tested presumptively positive for marijuana. Jennifer’s purse was also in the vehicle and contained pills later identified as hydrocodone. During the car search, dispatch confirmed that the criminal no-contact order against Steven was active. Steven was taken into custody; Jennifer was arrested for possession of drug paraphernalia, and a subsequent search of her person revealed another syringe and a baggie of methamphetamine hidden in her bra. The State charged Jennifer with possession of methamphetamine, possession of hydrocodone, possession of marijuana, and possession of drug paraphernalia, as well as a persistent violator enhancement. The district court concluded the officers had no lawful basis to continue detaining Jennifer, a passenger in a vehicle, after officers abandoned the original purpose of the traffic stop in order to investigate whether the driver was in violation of a criminal no contact order barring him from being with Jennifer. On appeal, the State argued that reasonable suspicion a driver is engaged in criminal conduct not only allows officers to extend a traffic stop and detain the driver, but it also includes the continued lawful detention of all passengers. To this, the Idaho Supreme Court concurred and reversed the district court's suppression order.
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