State v. John A. Urresti
Background
- Officers blocked a street around an aggravated-assault investigation with patrol vehicles; some had hazard lights on.
- Urresti attempted to drive his pickup between the blocking vehicles; an officer directed him to back up and then to stop.
- When the officer approached and Urresti rolled down his window, the officer smelled alcohol and perceived abnormal responses; breath tests later showed .250 and .242.
- Urresti was charged with DUI and moved to suppress, arguing the stop/seizure violated the Idaho and U.S. Constitutions.
- The magistrate denied suppression, stating (in language the defendant later challenged) that the evidence was viewed in a light most favorable to the State.
- On intermediate appeal the district court affirmed on two alternative grounds: (1) the magistrate’s remark could be read as a correct legal standard—or any error was harmless; and (2) the stop was justified either by the roadblock/obstruction rule or by the police community-caretaking function. Urresti appealed but did not challenge the district court’s alternative holdings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the magistrate applied the correct legal standard when denying the suppression motion | State: magistrate’s remark reasonably read as evaluating the officer’s perceptions at the time (a correct standard) | Urresti: magistrate misstated law by saying he viewed the case "in a light most favorable to the State" | Court: affirmed on uncontested alternative—harmless error; did not decide mistaken-standard claim because Urresti failed to challenge harmless-error holding on appeal |
| Whether the officer unlawfully seized Urresti after he backed away from the scene | State: stop justified by obstruction/roadblock into a crime-investigation zone and by community-caretaking function | Urresti: stop unlawful and analogous to Henderson roadblock precedent; any justification dissipated once he retreated | Court: affirmed on uncontested alternative—stop was justified under community-caretaking function; did not address Henderson claim because Urresti failed to challenge the alternative holding |
Key Cases Cited
- State v. Korn, 148 Idaho 413 (discussing appellate standard for district review of magistrate findings)
- State v. Trusdall, 155 Idaho 965 (appellate procedure: courts review district court affirmance of magistrate)
- State v. Zichko, 129 Idaho 259 (issues unsupported by legal argument will not be considered)
- State v. Raudebaugh, 124 Idaho 758 (issues raised first in reply brief are forfeited)
- Morrison v. St. Luke's Regional Med. Ctr., Ltd., 160 Idaho 599 (when a lower court rules on two alternative grounds, appellate court may affirm on uncontested ground)
- State v. Grazian, 144 Idaho 510 (same principle regarding alternative grounds)
- State v. Henderson, 114 Idaho 293 (roadblock case relied on by defendant)