State v. Jesse Eugene Mann, 162 Idaho 36

Mann was driving a rental car rented to his partner when stopped for an insufficient lane-signal; his license was suspended and he was arrested for driving without privileges.
The rental agreement did not list Mann as an authorized driver; the lessee (his partner) had rented the car.
Trooper Clark conducted a department policy inventory search before towing the vehicle and found a pipe, a toffee‑like substance, and bags of a plant-like substance later tested as 5.38 pounds of marijuana.
Mann was charged with trafficking marijuana, driving without privileges, and possession of drug paraphernalia; he moved to suppress the evidence from the vehicle search.
The district court denied suppression under the Court of Appeals’ Cutler totality-of-the-circumstances test; a jury convicted Mann on all counts.
On appeal the Idaho Supreme Court affirmed, adopting a bright-line rule that unauthorized drivers listed by the rental company lack a reasonable expectation of privacy in the rental vehicle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mann had standing (reasonable expectation of privacy) to challenge the inventory search of a rental car he was not authorized to drive	State: Mann lacked standing because he was not an authorized driver under the rental agreement	Mann: He had permission from the lessee (his partner) to drive the car and thus had a reasonable expectation of privacy; alternatively, totality factors or a modified test should permit standing	Court: Adopted bright-line test — unauthorized drivers not listed on the rental agreement lack standing; affirmed denial of suppression
Whether jury instruction/response to jury question on paraphernalia required proof that intent to use occurred in Idaho	State: The statute requires possession in Idaho with intent to use; it is not required that intent be formed in Idaho	Mann: The State must prove he intended to use the paraphernalia while in Idaho (or at least that his intent to use was tied to Idaho)	Court: Instruction (ICJI-based) correctly required possession in Idaho and intent to use; it did not matter where the intent was formed; no reversible error

State v. Cutler, 144 Idaho 272 (Ct. App.) (adopted totality-of-the-circumstances test for unauthorized rental‑car drivers)
Rakas v. Illinois, 439 U.S. 128 (1978) (defendant must show reasonable expectation of privacy to challenge a search)
United States v. Smith, 263 F.3d 571 (6th Cir. 2001) (articulated five-factor totality test for unauthorized rental‑car drivers)
United States v. Thomas, 447 F.3d 1191 (9th Cir. 2006) (modified bright-line test: permission from lessee can confer standing)
United States v. Jones, 44 F.3d 860 (10th Cir. 1995) (bright-line rule denying standing to drivers not authorized by rental agreement)