Idaho v. Miramontes
Annotate this CaseProbation officers detained Natalie Miramontes while conducting a residence check on a female probationer, Christine Evans. During the detention, probation officers searched Miramontes’ purse and found suspected drug paraphernalia. Probation officers paused the search and contacted police. Once police arrived, officers resumed the search and, inside a pantry converted to a spare bedroom, they uncovered more drug paraphernalia and a substance that tested presumptively positive for methamphetamine. Miramontes told police she had been sleeping inside the spare room. Miramontes moved to suppress all evidence found during her detention. The district court denied her motion. Miramontes entered a conditional guilty plea and reserved her right to appeal. She appealed, and the Court of Appeals affirmed her conviction. Miramontes petitioned the Idaho Supreme Court for review, arguing the district court erred when it denied her motion to suppress because officers searched her purse without reasonable and articulable suspicion. She also argued the items found during the later search of the spare bedroom would not have been inevitably discovered without the unlawful search of her purse. The Supreme Court reversed the district court’s decision denying Miramontes’ motion to suppress and remanded for fact-finding on whether Miramontes was unlawfully searched.
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