State v. Cara E. Williams
Background
- Officer Cowell investigated a vehicle parked partly in the roadway and activated rear amber lights; occupants were Cleocha Spraggins (driver) and Cara Williams (passenger).
- Dispatch advised both individuals’ driver’s licenses were suspended; Cowell told them to contact someone with a valid license to remove the vehicle and transport them, and did not arrest or cite them.
- Cowell asked for consent to search; Williams refused. Cowell then requested a canine unit. Williams became agitated; Cowell read Miranda warnings and later directed her to sit and stop talking.
- A drug dog alerted on the vehicle; Cowell searched and found drug paraphernalia in Williams’s purse.
- Williams moved to suppress, arguing she was seized without reasonable suspicion when Cowell requested the canine unit; the district court denied the motion. Williams pleaded guilty but reserved the right to appeal the suppression denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams was "seized" under the Fourth Amendment when Officer Cowell requested a canine unit | Requesting the canine unit converted a consensual encounter into a seizure before reasonable suspicion existed | Cowell’s request did not restrain liberty; he never used force or a show of authority and had told them they were free to leave | Court held Williams was not seized when Cowell requested the canine unit; encounter remained consensual |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (framework for investigative stops and seizures)
- United States v. Mendenhall, 446 U.S. 544 (1980) (circumstances indicating a seizure include presence of multiple officers, display of weapon, physical touching, or language conveying compulsion)
- Florida v. Bostick, 501 U.S. 429 (1991) (consensual encounters vs. seizures; police may approach and ask questions)
- Florida v. Royer, 460 U.S. 491 (1983) (detention occurs when a reasonable person would not feel free to leave)
- Miranda v. Arizona, 384 U.S. 436 (1966) (requirement to advise of rights when custodial interrogation occurs)
- State v. Henage, 143 Idaho 655 (2007) (objective test for seizure under Idaho law)
- State v. Willoughby, 147 Idaho 482 (2009) (factors such as emergency lights or blocking exits may indicate a seizure)