State v. Bonner, 467 P.3d 452

Officer in a marked Boise patrol car followed a red Volkswagen Jetta after observing it pass at speed and displaying a temporary registration; he suspected evasive behavior but did not initiate a traffic stop for speed.
The Jetta exited to a largely empty St. Luke’s Hospital parking lot and parked far from the outpatient building; the driver (Bonner) left the vehicle, tried locked doors of a dark outpatient building, then walked away from both the building and the car.
Officer approached Bonner, asked for ID, and—after Bonner fumbled for items and did not immediately answer whether the Jetta was his—ordered him to sit on the curb (the parties agree this was the seizure).
Dispatch told the officer Bonner’s license was suspended; Bonner admitted parole for a prior DUI; Bonner was arrested for driving without privileges and later tested .092 for alcohol.
Bonner moved to suppress evidence, arguing the curb-order was an unlawful seizure lacking reasonable suspicion; the district court granted suppression. The State appealed and the Idaho Supreme Court reversed, holding the detention was supported by reasonable suspicion under the totality of circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable articulable suspicion to detain Bonner	Officer observed evasive conduct (lane changes, parking far from building, trying locked doors, walking away from car) and inability to read temp tag—totality supports suspicion of vehicle-related crime	Conduct was ambiguous; at seizure Bonner was standing, responsive, not fleeing—state had at most a hunch	Reversed suppression: reasonable suspicion existed based on totality and evasive behavior, so brief investigative detention was lawful
Whether Bonner’s parole waiver eliminated his Fourth Amendment challenge	Parole waiver consented to warrantless searches, so no reasonable expectation of privacy	Waiver ineffective if officer did not know parole status at time of seizure; Bonner retains standing	Court did not decide; held unnecessary because detention and subsequent arrest were supported independently by reasonable suspicion/probable cause
Whether encounter was consensual or a seizure before asking dispatch	Initial contact was consensual or justified; any detention was supported by reasonable suspicion	The officer’s instruction to sit converted the encounter into a seizure lacking justification	Court accepted that ordering to sit was a seizure but found it justified by reasonable suspicion; did not need to resolve consensual-contact claim

Terry v. Ohio, 392 U.S. 1 (1968) (establishes stop-and-frisk investigatory stop standard requiring specific and articulable facts)
Illinois v. Wardlow, 528 U.S. 119 (2000) (evasive behavior is a relevant factor in reasonable-suspicion analysis)
United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-the-circumstances test; reasonable suspicion is a lesser standard than probable cause)
Wong Sun v. United States, 371 U.S. 471 (1963) (addresses limits on relying on vague, untested information for probable cause)
United States v. Sokolow, 490 U.S. 1 (1989) (distinguishes a hunch from constitutionally sufficient reasonable suspicion)
United States v. Cortez, 449 U.S. 411 (1981) (articulates totality-of-the-circumstances approach to reasonable suspicion)
State v. Bishop, 146 Idaho 804 (2009) (Idaho precedent on reasonable articulable suspicion standard)
State v. Cook, 165 Idaho 305 (2019) (holding that temporary license-plate display alone does not necessarily create reasonable suspicion)