State v. Chad Lee Williams
162 Idaho 56
| Idaho Ct. App. | 2016Background
- Boise police surveilled an apartment to arrest a third-party subject on a valid arrest warrant; officers watched one person enter and four exit and stand by the doorway.
- When officers shined a flashlight on the wanted subject, he fled into the apartment and out the back; officers chased and arrested him at the rear.
- Officers at the front detained three remaining individuals, including Chad Williams, for identification and to determine if they were harboring the suspect.
- While returning from the arrest, an officer smelled a strong odor of marijuana coming from the apartment and the apartment owner admitted there was marijuana and paraphernalia inside.
- Williams was arrested for frequenting a place where controlled substances are known to be located; a search incident to arrest produced methamphetamine, marijuana, and paraphernalia.
- Williams moved to suppress; the district court denied the motion and Williams appealed after a conditional guilty plea.
Issues
| Issue | State's Argument | Williams' Argument | Held |
|---|---|---|---|
| Lawfulness of initial detention during execution of an arrest warrant for a third party | Detention of on‑site third parties is permissible under Summers/Buie rationale to control the scene and protect officers | Detention was unlawful because detention of unrelated third parties during an arrest warrant execution is not justified; court relied improperly on search-warrant cases | Detention was constitutionally permissible as de minimis intrusion analogous to Summers and related authorities; valid until suspect was secured and officer custody known |
| Alternative basis: investigatory detention for harboring a felon | Officers had reasonable articulable suspicion (presence in apartment, suspect fled) to investigate harboring and detain temporarily | Williams argued detention should have been only seconds and lacked sufficient basis | Detention was justified at inception by reasonable suspicion to investigate harboring and questioning to establish identity/relationship was proportional |
| Whether detention was unreasonably prolonged | New, independent basis arose (odor of marijuana + owner’s admission), justifying continued detention to investigate frequenting | Williams contended identity questioning should have taken seconds and was prolonged beyond justification | Detention was not unreasonably prolonged—investigation and subsequent marijuana inquiry were reasonable and related to purposes of the stop |
| Probable cause for arrest for frequenting a place with controlled substances | Smell of marijuana, owner’s admission, and Williams’ prolonged presence in apartment supported probable cause | Williams argued no probable cause for frequenting; arrest unlawful so search incident to arrest should be suppressed | Probable cause existed to arrest Williams for frequenting; search incident to that lawful arrest produced admissible evidence |
Key Cases Cited
- Michigan v. Summers, 452 U.S. 692 (establishes detention of occupants during execution of a search warrant to control the scene)
- Maryland v. Buie, 494 U.S. 325 (authorizes limited protective sweeps/detentions to ensure officer safety during arrests)
- United States v. Maddox, 388 F.3d 1356 (10th Cir.) (applies Buie/Summers reasoning to detain third parties during execution of an arrest warrant)
- Terry v. Ohio, 392 U.S. 1 (authorizes brief investigatory stops based on reasonable articulable suspicion)
- Wilson v. Maryland, 519 U.S. 408 (addresses officer authority in traffic/occupant detentions during investigations)
- United States v. Sharpe, 470 U.S. 675 (permissible duration of investigative stops; brevity favors reasonableness)
- Brinegar v. United States, 338 U.S. 160 (defines probable cause standard)
- State v. Reynolds, 143 Idaho 911, 155 P.3d 712 (Idaho Ct. App.) (detention of third parties during search warrant execution analyzed and relied upon by the court)