State v. Clark, 484 P.3d 187

Police responded to a reported robbery at a Grangeville mobile home park and encountered William Clark among persons on the scene. Dispatch advised Clark had an outstanding felony bench warrant from Nez Perce County.
Officers attempted to arrest Clark; he fled, slipping out of handcuffs and evading two taser deployments. Officers pursued him through the park, briefly losing sight but continuing pursuit.
While fleeing, Clark entered two occupied trailers without the owners’ consent; one resident told officers Clark ran next door into her father’s locked home.
Officers later obtained a key, found Clark hiding under a bed, and arrested him; the outstanding felony warrant was served.
Clark was tried in a bench trial on two counts of unlawful entry (enhanced to felonies under Idaho Code § 18-7034(2) if committed while being pursued), resisting/obstructing, and providing false information; the court acquitted on the false-information charge, convicted of resisting (later dismissed), and found Clark guilty of two counts of felony unlawful entry after concluding the pursuit satisfied the statutory “fresh pursuit” definition.
On appeal Clark argued the statutory/common-law concept of “fresh pursuit” does not include pursuit to execute an outstanding arrest warrant and that evidence was insufficient to prove the felony enhancement; the Idaho Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the statutory definition of “fresh pursuit” (I.C. § 19-705) includes pursuit to execute a valid arrest warrant	The State: yes — a felony arrest warrant reflects a magistrate’s probable-cause finding, so officers reasonably suspected Clark committed a felony and pursuit to execute the warrant is "fresh pursuit."	Clark: no — "has committed" means contemporaneous commission; the statute requires pursuit tied closely in time to the felony, so pursuing to execute a prior warrant is excluded.	The Court: statutory "fresh pursuit" includes pursuit to execute a valid arrest warrant; existence of the warrant supplies the requisite objective basis.
Sufficiency of evidence for felony unlawful entry (I.C. § 18-7034(2))	The State: testimony established two nonconsensual entries while officers were in continuous pursuit and the felony warrant was produced.	Clark: argued the pursuit element was not proven because pursuit to execute a warrant is not covered and there was no evidence they suspected him of the robbery.	The Court: evidence was sufficient; findings were not clearly erroneous and support conviction on two counts of felony unlawful entry.

State v. Gomez-Alas, 167 Idaho 857, 477 P.3d 911 (explaining appellate standard for sufficiency review)
Porcello v. Estate of Porcello, 167 Idaho 412, 470 P.3d 1221 (deference to trial court findings after bench trial)
State v. Sheahan, 139 Idaho 267, 77 P.3d 956 (evidence viewed in light most favorable to prosecution on appeal)
State v. Schwarz, 133 Idaho 463, 988 P.2d 689 (officer knowledge of an outstanding warrant supplies probable cause)
State v. Ballou, 145 Idaho 840, 186 P.3d 696 (discussing hot/fresh pursuit as Fourth Amendment exception)
State v. Burnight, 132 Idaho 654, 978 P.2d 214 (statutory construction principles governing plain language)