State v. Alesha Ann Green, 158 Idaho 884

Ada County officer stopped Green for failing to maintain lane; Green admitted driving with an invalid license.
Officer arrested Green despite misdemeanor status not arrestable under Idaho law under the circumstances; search incident to arrest yielded drugs, paraphernalia, and cash.
Green was charged in two cases; district court suppressed the evidence, ruling the arrest violated Article I, Section 17 of the Idaho Constitution.
State appealed; district court found the arrest unreasonable because it did not comply with Idaho Code § 49-1407.
Court analyzes whether an arrest that is lawful under federal standards but violates Idaho statute can be constitutional under Idaho Constitution, citing Rauch, Mathews, Card; ultimately holds no constitutional violation and that suppression is inappropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the misdemeanor arrest under I.C. § 49-1407 unconstitutional under Art. I, §17?	Green argues statutory violation impacts constitutional rights	State argues Idaho follows federal standards unless unique Idaho principles apply	No constitutional violation; arrest lawful under Idaho Constitution
If not, should evidence seized incident to the arrest be suppressed?	Green seeks suppression as remedy for statutory violation	State argues suppression is not required for statutory violations lacking constitutional violation	Suppression not warranted; remand for further proceedings

Chimel v. California, 395 U.S. 752 (U.S. 1969) (authorization of search incident to lawful arrest)
Virginia v. Moore, 553 U.S. 164 (U.S. 2008) (police may rely on probable cause for a lawful arrest even if statutes differ)
California v. Acevedo, 500 U.S. 565 (U.S. 1991) (focus on warrant exceptions and searches of effects)
Rauch, 99 Idaho 586 (Idaho 1978) (knock-and-announce and preconstitutional protections; suppression as remedy)
Mathews, 129 Idaho 865 (Idaho 1997) (pre-existing constitutional principles; statutory violations can be constitutional violations when rooted in pre-Constitution rights)
Card, 137 Idaho 182 (Idaho 2002) (statutory scheme supplemented constitutional rights; suppression may follow statutory violations)
Branigh, 155 Idaho 404 (Ct. App. 2013) (later decisions limit suppression to constitutional violations, not mere statutory violations)
Hart, 66 Idaho 217 (Idaho 1945) (pre-Constitution arrest standards informing reasonableness under Art. I, §17)
Guzman, 122 Idaho 981 (Idaho 1992) (exclusionary rule context for constitutional violations)