State v. Bills, 463 P.3d 412

Officers received a tip about drug trafficking at Bills' residence; garbage pulls allegedly tested presumptively positive for heroin, and a search warrant was obtained for the home, vehicles, and curtilage.
During execution of the warrant, Bills was handcuffed in the hallway and taken outside; an officer noticed a bulge in her front-right pants pocket.
After asking whether she had anything that could injure officers, the officer reached into her pocket, removed a clear cylindrical tube containing a substance that appeared to be heroin and a separate small bag appearing to be methamphetamine.
After the seizure, an officer read Bills her Miranda rights and questioned her; Bills described the dark substance as "black" (slang for heroin) and speculated the white powder might be bath salts.
Bills moved to suppress, arguing the search of her person was unlawful and any statements resulting from the illegal search should be excluded. The trial court found the pat-down/search unreasonable but admitted the drugs under the inevitable-discovery doctrine and allowed statements made after Miranda; pre‑Miranda statements were suppressed.
Bills entered a conditional guilty plea reserving the right to appeal the suppression ruling; the appellate court reversed, vacated convictions, and remanded.

Issue	Bills' Argument	State's Argument	Held
Whether statements Bills made when confronted with drugs seized during an unlawful search are admissible	Statements are "fruit of the poisonous tree" and must be suppressed (relying on State v. Luna and State v. Downing)	Physical evidence was admissible under inevitable discovery; the statements would have inevitably been made and thus are admissible	Reversed: statements are inadmissible. Inevitable discovery of physical evidence does not render statements admissible; each item (physical evidence and statements) requires its own basis for admissibility. Luna and Downing control

State v. Luna, 880 P.2d 265 (Idaho Ct. App. 1994) (statements made after confrontation with evidence from an illegal search are fruit of the poisonous tree and generally inadmissible)
State v. Downing, 407 P.3d 1285 (Idaho 2017) (confessions or admissions elicited after an unreasonable search of the person are inadmissible where no intervening factor breaks the causal chain)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requirement to advise detainees of rights before custodial interrogation)