State v. Irvin C. Ray
286 P.3d 1114
Idaho2012Background
- Ray moved to suppress evidence from his backpack as the suppression motion followed an unlawful detention claim.
- A state trooper pulled over two vehicles after stopping the lead Subaru and parking behind it, with the Toyota nearby.
- The trooper walked from his patrol car toward the Toyota to tell the driver they were free to go after stopping the Subaru.
- The district court ruled that walking toward the Toyota constituted a seizure without reasonable suspicion.
- The district court’s suppression ruling was orally given and then reduced to a written order, and the case was dismissed.
- Appellate review proceeded de novo on the suppression issue, with briefing addressing Fourth Amendment standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did walking toward the Toyota constitute a seizure? | Ray asserts the act of walking toward the Toyota restrained movement. | State argues no seizure occurred; approaching a vehicle does not necessarily seize occupants. | No seizure; walking toward the Toyota did not restrain movement under the circumstances. |
| Does Idaho Code § 49-625(1) create a seizure when emergency lights are on and a vehicle is stopped? | Ray contends the stop complied with the statute but the approach violated free movement. | State contends the statute permits remaining stopped until the vehicle passes, and a show of authority is required to seize. | Driver compliance with 49-625(1) does not by itself create a seizure; approach alone does not convert into seizure. |
Key Cases Cited
- Florida v. Royer, 460 U.S. 491 (1983) (approaching individuals does not always constitute seizure)
- Michigan v. Chesternut, 486 U.S. 567 (1988) (show of authority requires restraint to be a seizure)
- Willoughby, 147 Idaho 482, 211 P.3d 91 (2009) (emergency lights contribute to totality of circumstances in seizure analysis)
- Drayton, 536 U.S. 194 (2002) (briefly questioned individuals; not always seizure)
- Osborne, State v. Osborne, 121 Idaho 520, 826 P.2d 481 (1991) (totality of circumstances governs whether encounter is seizure)
- Henage, 143 Idaho 655, 152 P.3d 16 (2007) (objective totality framework for seizures)