Idaho v. Towner
Annotate this CaseGregory Wade Towner, Sr., appealed his conviction for possession of methamphetamine. The arresting officer found the contraband on Towner’s person during a warrantless search. Towner moved to suppress, arguing that the officer’s conduct violated his constitutional rights against unreasonable search and seizure. The district court denied Towner’s motion after concluding that the officer’s seizure and subsequent search were a reasonable exercise of the officer’s community caretaking function. Towner appealed and the Idaho Court of Appeals affirmed. The Idaho Supreme Court granted Towner’s petition for review, and reversed, finding the trial court erred in concluding the officer's act of taking Towner into protective custody was within the officer’s authority under the community caretaker exception to the Fourth Amendment without considering the requirements of Idaho Code section 66-326(1). The case was remanded with instructions for the trial court to enter findings of fact related to whether the State proved that Towner was “gravely disabled” or an “imminent danger” to himself or others because of his mental illness under Idaho Code section 66-326(1), before he was taken into protective custody.
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