State v. Debra Joan Noeller
Background
- Officer stopped Noeller’s Arizona‑plated vehicle on I‑86 for suspected illegal window tinting under I.C. § 49‑944; officer had a tint meter but did not use it during the stop.
- Officer asked for license, registration, and insurance; records checks showed no warrants; passenger explained vehicle belonged to his wife; both occupants were calm and showed no signs of drug use.
- Officer requested backup to deploy a drug dog based on a suspicion of drug activity; the initial officer then handed the stop to a second officer and abandoned the window‑tint inquiry.
- The second officer removed occupants, kept their documents, deployed a drug dog (which failed to alert), and continued questioning; occupants were not told they were free to leave.
- After continued questioning, Noeller consented to a vehicle search; methamphetamine was found in her purse and later ~500 grams were found in the bumper; Noeller moved to suppress.
- The district court suppressed, reasoning I.C. § 49‑944 applies only to Idaho‑registered vehicles; the State appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether I.C. § 49‑944(2) authorizes a stop of an out‑of‑state vehicle for suspected illegal tint | § 49‑944 applies to any vehicle operated on Idaho public highways; plain language covers any person/vehicle in Idaho | § 49‑944 should be read like Morgan — vehicle equipment laws apply only to vehicles registered in Idaho; out‑of‑state registration implies compliance with home state rules | Court: statute applies to any vehicle operated in Idaho; district court erred in holding otherwise |
| Whether officers lawfully extended the stop to deploy a drug dog | Stop was properly extended because officer had reasonable suspicion of drug activity | Stop was unlawfully extended — officers abandoned the traffic inquiry and pursued a drug investigation without reasonable suspicion | Court: officers abandoned the traffic purpose and unlawfully extended the stop; extension was not justified |
| Whether Noeller’s consent to search was voluntary and therefore validated the search | Consent was voluntary, so evidence should not be suppressed | Consent was tainted by the unlawful extension and therefore ineffective | Court: consent was tainted by the illegal detention and ineffective; suppression affirmed |
| Whether there is a sufficient record to affirm on the alternative ground despite district court not addressing it | Sufficient facts were developed at the suppression hearing to decide the extension/consent issues on appeal | District court didn’t make findings, so appellate court shouldn’t decide alternative ground | Court: adequate factual record exists; appellate court may affirm on this alternative theory |
Key Cases Cited
- State v. Morgan, 154 Idaho 109 (2013) (distinguishing vehicle‑display statutes that apply only to Idaho‑registered vehicles)
- State v. Aguirre, 141 Idaho 560 (2005) (holding officers impermissibly extended a traffic stop by abandoning the stop’s purpose to pursue a dog sniff)
- State v. Parkinson, 135 Idaho 357 (2000) (permitting concurrent traffic and narcotics inquiries where stop duration is not extended)
- Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (party asserting consent bears burden to show voluntariness under totality of circumstances)
- Terry v. Ohio, 392 U.S. 1 (1968) (framework for assessing permissible scope and duration of investigative stops)
- Florida v. Royer, 460 U.S. 491 (1983) (consent obtained during an unlawful detention may be tainted and ineffective)
- Delaware v. Prouse, 440 U.S. 648 (1979) (traffic stops implicate Fourth Amendment protections)
- United States v. Cortez, 449 U.S. 411 (1981) (reasonable‑suspicion standard judged under the totality of the circumstances)