State v. Fredrick D. Roy

Officer stopped a vehicle after observing a taillight emitting white light; Roy was a passenger.
Officer discovered suspected marijuana in the rear seat area and learned the driver’s license was suspended; both occupants were ordered out of the vehicle.
While waiting, Roy was repeatedly told to keep his hands out of his pockets; he was handcuffed after failing to comply and an officer pulled a metal tin from his pocket, finding three .22 rounds (the tin’s contents were later suppressed).
A subsequent search of the vehicle uncovered marijuana and a Winchester Model 39 .22 firearm under the front passenger seat where Roy had been sitting; a bolt matching the firearm was found on the pavement.
Roy, a convicted felon, was charged with unlawful possession of a firearm; he moved to suppress evidence and filed a motion in limine to exclude anticipated witness testimony; the district court granted suppression of the tin’s contents but denied suppression regarding the bolt and firearm and denied the motion in limine.
Roy entered a conditional guilty plea reserving the right to appeal the partial suppression denial and the in limine ruling; the Court of Appeals affirmed the district court.

Issue	Roy's Argument	State's Argument	Held
Whether officer had reasonable suspicion to stop vehicle for taillight violation	Taillight emitted white light but stop was not justified because the light was not sufficiently defective	Statutes require taillamps to emit red light; emitting white light violates the law and gives reasonable suspicion	Stop was justified; reasonable suspicion existed based on white light emission
Admissibility of witness testimony about prior possession/identification of a similar firearm	Testimony is irrelevant to possession on arrest date and, if relevant, unduly prejudicial because witness did not positively identify weapon earlier	Prior possession of a distinctive weapon and anticipated in-court identification is relevant and probative; any discrepancy goes to weight, not admissibility	Testimony admissible; district court did not abuse discretion under I.R.E. 403

State v. Atkinson, 128 Idaho 559 (Ct. App. 1996) (standard of review for suppression motions)
State v. Patterson, 140 Idaho 612 (Ct. App. 2004) (taillight emitting white light justified investigatory stop)
State v. Bradshaw, 155 Idaho 437 (Ct. App. 2013) (standards for overturning precedent)
State v. Boehm, 158 Idaho 294 (Ct. App. 2015) (abuse of discretion review for motions in limine)
State v. Hedger, 115 Idaho 598 (1989) (multi-tiered inquiry for discretionary rulings)
State v. Stevens, 146 Idaho 139 (2008) (definition of relevance under Rule 401)
State v. Enno, 119 Idaho 392 (1991) (I.R.E. 403 abuse-of-discretion standard)