State v. Brent Jacob Tyler
153 Idaho 623
| Idaho Ct. App. | 2012Background
- Tyler was a passenger in a vehicle stopped for an illegal U-turn; officer conducted a probation-related search of the driver and the vehicle.
- Tyler admitted having a knife; he moved his jacket to reveal the knife in his left pocket; officer asked to pat him down for weapons.
- Tyler agreed to a Terry stop-and-frisk; officer removed the knife from his left pocket and then patted the right pocket under two jackets.
- While patting, the officer felt and removed a syringe later believed to contain methamphetamine; Tyler was arrested and additional drugs and a bag were found.
- Tyler moved to suppress the syringe and subsequent findings as beyond the scope of a pat-down; the district court suppressed the evidence.
- The district court held the frisk exceeded the scope of a Terry pat-down, relying on a belief that outer clothing limits applied; the State appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of Terry frisk beyond outer clothing | State contends Terry allows broader intrusion or consent-based expansion. | Tyler argues frisk was limited to outer clothing; no justification to reach under jackets. | Terry frisk is generally limited to outer clothing; no justification to intrude under clothing here. |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (Supreme Court 1968) (frisk limited to outer clothing to assess weapons for officer safety)
- Florida v. Jimeno, 500 U.S. 248 (Supreme Court 1991) (scope of consent-based searches measured by objective reasonableness)
- State v. Crooks, 150 Idaho 117, 244 P.3d 261 (Ct. App. 2010) (Terry frisk framework and outer clothing scope in Idaho)
- State v. Bishop, 146 Idaho 804, 203 P.3d 1203 (Ct. App. 2009) (reiterates outer clothing frisk limitations)
- State v. Greene, 140 Idaho 605, 97 P.3d 472 (Ct. App. 2004) (frisk defined as carefully limited search of outer clothing; exceptions are strict)
- State v. Muir, 116 Idaho 565, 777 P.2d 1238 (Ct. App. 1989) (framework for assessing reasonableness of searches and intrusions)
- State v. Kilby, 130 Idaho 747, 947 P.2d 420 (Ct. App. 1997) (consent standard and burden of proof in searches)
- State v. Ballou, 145 Idaho 840, 186 P.3d 696 (Ct. App. 2008) (consent scope and objective reasonableness in searches)
- Knapp v. State, 120 Idaho 343, 815 P.2d 1083 (Ct. App. 1991) (consent and scope of searches principles)