Idaho v. RandallAnnotate this Case
A drug dog leapt into defendant-appellant Jacob Randall’s rental car during what was supposed to have been an exterior sniff. After the dog alerted to the presence of narcotics, officers searched the car and discovered 65 pounds of marijuana. Relying on an Idaho Court of Appeals case providing that a drug dog’s “instinctive” actions did not violate the Fourth Amendment, the district court denied Randall’s motion to suppress evidence of the marijuana because it found the dog’s entry was instinctive. The Idaho Supreme Court reversed, finding the rule articulated by the Court of Appeals and applied by the district court was inconsistent with the Fourth Amendment.