State v. Jamie Lynn Pachosa, 368 P.3d 655

On Oct. 22, 2014, officers responded to a report of a red sports car sitting in a park lot late at night; officer encountered a male driver and female passenger (Pachosa).
Pachosa gave a false name and inconsistent birth dates; dispatch could not locate the name/date entries initially, though the driver’s information did return.
Officer handcuffed and detained Pachosa after repeated conflicting identification; dispatch later produced a record that matched a different middle name and then confirmed a Washington warrant for Pachosa.
A makeup bag handed from the vehicle contained a glass pipe; a subsequent search of Pachosa’s purse revealed foil, phones, a wallet showing her true name, and later a vial testing presumptively positive for methamphetamine.
Pachosa moved to suppress all evidence, arguing the officers lacked reasonable suspicion for the investigatory detention; the district court granted suppression relying on State v. Zuniga and found detention unsupported.
The State appealed; the Idaho Supreme Court vacated the suppression order and remanded for the district court to reconsider reasonable-suspicion under the totality of circumstances (not bound by Zuniga).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pachosa)	Held
Whether officers had reasonable articulable suspicion to detain Pachosa after inconsistent ID info	Detention was justified by totality: late-night suspicious stop near known drug location, inaccurate/unverifiable ID despite database that would have returned correct info	No reasonable suspicion: providing a name that initially didn’t return in database (and differing DOBs) is insufficient to detain absent other corroboration (relying on Zuniga)	Vacated district court suppression; remanded to assess reasonable suspicion under totality of circumstances — Zuniga does not automatically require suppression
Whether State v. Zuniga compelled suppression here	Zuniga is distinguishable because the database here would have returned results if ID was accurate; officers had more to rely on	Zuniga controls and dictates that lack of a database hit alone cannot justify detention	Court held Zuniga did not control; district court erred to treat it as binding and must reassess facts on remand

State v. Zuniga, 143 Idaho 431 (Ct. App. 2006) (court of appeals held that a name not appearing in a database, by itself, was insufficient to support reasonable suspicion)
State v. Hankey, 134 Idaho 844 (Idaho 2000) (standard of review for legal effect of undisputed facts on suppression)
State v. Bishop, 146 Idaho 804 (Idaho 2009) (limited investigatory detentions require reasonable articulable suspicion)
State v. Nickel, 134 Idaho 610 (Idaho 2000) (definition of a seizure under the Fourth Amendment)
State v. Willoughby, 147 Idaho 482 (Idaho 2009) (burden on defendant to prove a seizure occurred)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes investigatory stop/scope reasonableness framework)