Idaho v. Plata Iniguez
Annotate this CaseOfficers from the Boise Police Department arrested Eduardo Plata Iniguez (“Plata”) outside his home for misdemeanor driving under the influence (“DUI”) without a warrant, and without witnessing the commission of the alleged crime. Upon his arrest, Plata was transported to jail where evidentiary breath testing was administered. At the jail, Plata failed to provide an adequate breath sample. Thereafter, officers procured a warrant from an on-call magistrate judge for a search of Plata’s blood, performed a blood draw at the Jail, and obtained an evidentiary sample of his blood. The State charged Plata with misdemeanor DUI (second offense), and Plata moved to suppress the blood draw evidence as a product of his unlawful arrest under Idaho v. Clarke, 446 P.3d 451 (2019). The Idaho Supreme Court concluded Plata made an initial showing of a causal nexus; Idaho’s exclusionary rule did not include a reasonable “mistake of law” exception; and the State did not argue another established exception applied (e.g., inevitable discovery or attenuation). Thus, the blood draw evidence should have been suppressed as derivative fruit of Plata’s illegal arrest, and the decision of the district court was reversed.
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