Miller v. IDAHO STATE PATROL
150 Idaho 856
| Idaho | 2011Background
- Miller was arrested for DUI after Yount observed signs of intoxication and field sobriety tests were failed.
- At a hospital Miller refused to provide a urine sample, and a nurse catheterized him at Yount's request to obtain a specimen.
- Yount later found drug-related evidence on Miller and Miller admitted daily marijuana use.
- The district court denied summary judgment on Miller's § 1983 claim and allowed the ITCA tort claims to proceed, then granted a permissive appeal.
- This Court granted a permissive appeal and ultimately held Yount entitled to qualified immunity and the ISP entitled to ITCA immunity, with no genuine issues of material fact remaining.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Yount has qualified immunity under § 1983 for the catheterization. | Miller argues catheterization violated Fourth Amendment rights. | Yount contends law on forced catheterizations is unsettled; immunity applies. | Yount entitled to qualified immunity; Fourth Amendment issue not definitively decided. |
| Whether Yount is immune from Miller's tort claims under the ITCA. | Miller argues ITCA does not shield Yount from battery/assault. | Yount acted within duty and without malice; ITCA immunity applies. | Yount immune from battery and assault; ISP not liable for these claims. |
Key Cases Cited
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step framework for qualified immunity (now flexible))
- Pearson v. Callahan, 555 U.S. 223 (2009) (allows skipping constitutional question when appropriate)
- Anderson v. Creighton, 483 U.S. 635 (1987) (obvious inquiry into reasonable interpretation of law for immunity)
- Mitchell v. Forsyth, 472 U.S. 511 (1985) (court may decide immunity on legal grounds without resolving factual disputes)
- Halen v. State, 136 Idaho 829 (2002) (implied consent to BAC/drug testing; relevance to authority to require tests)