Idaho v. Hollist
Annotate this CaseBrian Hollist challenged a district court’s denial of his motion to suppress evidence. Hollist was arrested in Idaho Falls after an officer approached him while he was sleeping on a canal bank. The officer was responding to check on Hollist's welfare. After advising the officer he did not need medical assistance, Hollist attempted to leave several times; however, each time the officer insisted that Hollist remain. When Hollist declined to identify himself, the officer handcuffed him and ordered him to sit down on the grass. The officer later discovered that Hollist had an outstanding warrant for his arrest. Following his arrest, officers found a glass pipe with white residue and a bag with a small amount of methamphetamine inside. Before trial, Hollist moved to suppress the methamphetamine and pipe, arguing: (1) the officer was not performing a community caretaking function at the time he was detained; (2) the officer did not have reasonable suspicion to detain him; and (3) the eventual discovery of the arrest warrant did not purge the taint of his unlawful seizure. The district court denied Hollist’s motion to suppress. Hollist timely appealed. The Idaho Supreme Court concluded the officer did not have a reasonable suspicion to detain Hollist, and the officer's unlawful seizure of Hollist was not sufficiently attenuated from the discovery of contraband. The district court's denial of Hollist's motion to suppress was reversed and the matter reversed for further proceedings.
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