State v. Filip Danney, 153 Idaho 405

Ada County detective investigated Danney for marijuana trafficking based on an anonymous tip; trash contained marijuana residue, heat-sealed bags, and Danney’s alias; GPS device tracked Danney’s truck and placed Arcata, CA, as a source area; detective coordinated with a drug-detection dog during a traffic stop after a brief detention; dog alerted and marijuana was found; Danney was charged with trafficking in marijuana and moved to suppress GPS/search evidence; district court denied suppression and this denial was affirmed by the Court of Appeals; Idaho Supreme Court granted review on GPS foundation, reasonable suspicion, and GPS search issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was a proper foundation for GPS data	Danney contends GPS basis was lacking	Danney did not preserve challenge to GPS foundation	GPS foundation admissible for suspicion formation; not reviewable as preserved issue
Whether there was reasonable suspicion to extend the stop	Danney argues lack of basis for extended detention	Combined facts created reasonable suspicion	Yes; totality of circumstances supported reasonable suspicion justifying dog sniff detaining briefly

State v. Hansen, 151 Idaho 342 (2011) (reviewing suppression; bifurcated standard of review given to trial findings and law)
State v. Purdum, 147 Idaho 206 (2009) (clear error standard for factual findings; applied to suppression)
State v. Gallegos, 120 Idaho 894 (1991) (reasonable suspicion by totality of circumstances; police experience allowed inferences)
State v. Swindle, 148 Idaho 61 (2009) (relevance of officer training and experience in suspicions)
State v. Bishop, 146 Idaho 804 (2009) (reasonable suspicion standard; hearsay considerations)
Hankey, 134 Idaho 844 (2000) (anonymous tips may contribute to reasonable suspicion when corroborated)
U.S. v. Arvizu, 534 U.S. 266 (2002) (totality-of-the-circumstances approach to reasonable suspicion)
Sokolow, 490 U.S. 1 (1989) (reasonable suspicion standard based on articulable facts)
Florida v. Royer, 460 U.S. 491 (1983) (scope of investigative detention; limits on stop duration)
Rader, 135 Idaho 273 (Ct. App. 2000) (innocent explanations do not negate reasonable suspicion)