Idaho v. Pendleton
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Edo, a dog used by the Boise Police Department to detect controlled substances, alerted on defendant-respondent Shawna Pendleton’s vehicle during a traffic stop. Videos of the incident raised questions about the reliability of Edo’s performance. Through a series of discovery requests, Pendleton sought additional videos and police reports from past stops to challenge Edo’s reliability in detecting drugs. The district court, over repeated objections from the State, ultimately granted her motion to compel the evidence on finding it material to her defense.
On appeal, the State argued the district court abused its discretion by denying its motion for reconsideration because: (1) Pendleton failed to establish that the requested evidence was material to her defense; (2) the production of four-months’ worth of Edo’s reports and videos was unduly burdensome, and (3) not all of the requested evidence was within the prosecutor’s possession, custody, or control. The Idaho Supreme Court concluded the State failed to show an abuse of discretion in compelling production of the videos and reports regarding Edo and his handler for the four months prior to Pendleton’s arrest. The Supreme Court affirmed the district court’s determination that the evidence sought by Pendleton was material, not unduly burdensome, and in the “possession, custody or control” of the prosecution pursuant to Idaho Criminal Rule 16.
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