Phelps v. Ada County Sheriff Office
1:24-cv-00589
D. IdahoJun 3, 2025Background
- Aaron Lee Phelps alleged that Ada County Sheriff's Office personnel violated his Fourth Amendment rights during and after a traffic stop on August 22, 2023.
- Phelps claims he was detained longer than necessary after a traffic warning in order to facilitate a K-9 drug search, and that both the detention and search lacked reasonable suspicion.
- No criminal charges resulted from the traffic stop; only a warning for improper turn signal use was issued.
- Phelps also alleged officer misconduct related to a mobile data breach, document alteration, and conspiracy to interfere with his legal claims, but these were deemed too vague or not plausibly alleged.
- The court screened the complaint as required for inmates and indigent filers, concluding that only the Fourth Amendment claims for traffic stop and dog search could proceed against individual officers in their personal capacity.
- Service of process must be performed by Phelps, as he did not qualify to proceed in forma pauperis and must fund service personally.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of traffic stop | Stop lacked reasonable suspicion for failing to signal | (Not yet presented) | Allowed claim to proceed |
| Prolonged detention after stop | Detention after warning to wait for K-9 was unlawful | (Not yet presented) | Allowed claim to proceed |
| Dog search after completion of stop | K-9 search was unsupported by reasonable suspicion/warrant | (Not yet presented) | Allowed claim to proceed |
| Claims re: data breach, conspiracy, threats | Insufficiently pled claims of constitutional violations | (Not yet presented) | Must amend for clarity or dismissal |
| Claims against deceased officer & County | Named defendant is deceased; county liability insufficient | (Not yet presented) | Dismissed without amendment or allowed to amend |
| Claims against K-9 and by criminal statute | Police dog not liable; criminal statutes not actionable | (Not yet presented) | Dismissed; not cognizable under § 1983 |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (traffic stops are reasonable with probable cause of violation)
- United States v. Arvizu, 534 U.S. 266 (brief investigatory stops fall under Fourth Amendment)
- Brendlin v. California, 551 U.S. 249 (passenger/driver may assert Fourth Amendment claim on vehicle stop)
- Heien v. North Carolina, 574 U.S. 54 (reasonable mistake of law can justify a stop)
- Rodriguez v. United States, 575 U.S. 348 (dog sniff after completed stop is unlawful if it prolongs detention)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (local government liability under § 1983 requires policy/custom)