Idaho v. Wilson
Annotate this CaseIn December 2018, a Jack-in-the-Box employee suspected a “drunk driver” was in the restaurant’s drive-through line and reported this suspicion to law enforcement. An officer arrived on the scene and reported an odor of alcohol emanating from the passenger side of the vehicle, as well as empty alcohol containers on the floor near the vehicle’s passenger. The officer directed the driver, later identified as Andrew Wilson, to park the car. Wilson exited the vehicle. After noticing the odor of alcohol coming from Wilson, the officer began conducting field sobriety tests. The officer interpreted Wilson’s results as presenting signs of impairment. The officer then arrested Wilson for driving under the influence (DUI). A warrant for a blood draw was ultimately obtained after Wilson refused to submit to a breath test. The result of the blood draw conducted at the Pocatello Police Department reported a blood alcohol content of 0.192 percent. Wilson was charged with felony DUI based on two prior DUI convictions within the previous ten years. Wilson moved to suppress all evidence obtained as a result of his initial detention, arguing that the officer did not have reasonable suspicion to detain him in the restaurant parking lot. The district court granted Wilson’s motion and dismissed the charge against him with prejudice. The State appealed this decision to the Idaho Court of Appeals, which reversed the district court. The Idaho Supreme Court granted Wilson’s petition for review, and affirmed the district court’s decision to suppress because the State failed to preserve its argument for appeal. The Supreme Court found the State did not submit a responsive motion to Wilson's motion at the suppression hearing. "Allowing the State to argue on appeal that Officer Malone developed reasonable suspicion to detain Wilson prior to Wilson’s exit from the vehicle, when it implicitly conceded this point below, 'would sharply cut against our longstanding and recently re-affirmed policy of requiring parties to present their arguments to the court below[.]'"
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