State v. Johnson, 266 P.3d 1161

Johnson was convicted of trafficking in a controlled substance, possession of cocaine, and possession of drug paraphernalia.
She challenged a suppression ruling; district court granted suppression as to her purse but denied it as to the car.
A truck stop found a large quantity of drugs outside the bathrooms; an employee described a woman in her fifties with brown hair and hunched posture.
A gold/brown four-door sedan associated with the woman was observed loitering near the store; later a similar vehicle prompted a stop.
Johnson was in the back seat when stopped; officer discovered drugs and paraphernalia in the car and in Johnson's purse; Johnson was arrested.
Rule 35 motion for sentence reduction was denied as untimely; the filing date issue involved mailbox-rule consideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop of the vehicle was supported by reasonable suspicion	Johnson—no specific, articulable facts tying man to crime	State—facts accumulated show suspicion beyond a hunch	Yes, supported by totality of circumstances
Whether the vehicle search was lawful after Gant	Johnson—Gant limits the search incident to arrest	State—probable cause supported automobile exception	Probable cause supported automobile exception; search valid (originating from total circumstances)
Whether the Rule 35 motion timing was timely under mailbox rule	Mailbox rule should apply to Rule 35 filing for inmates	Timeliness determined by district court based on filing date	Mailbox rule applies; remand to determine timely submission; if timely, merits considered
Whether district court erred by denying suppression of Johnson's purse evidence	Evidence from purse should be suppressed	Purse evidence incidental to car search may be admissible	Affirmed suppression as to purse evidence was not clearly argued to reverse here

State v. Atkinson, 128 Idaho 559 (Ct.App. 1996) (standard for reviewing suppression findings: clear error on facts, de novo on law)
State v. Sheldon, 139 Idaho 980 (Ct.App. 2003) (reasonableness of investigative detention based on totality of circumstances)
State v. Valdez-Molina, 127 Idaho 102 (Ct. App. 1995) (credibility and inference in suppression determinations)
State v. Schevers, 132 Idaho 786 (Ct.App. 1999) (credibility and factual conflict resolution in suppression)
State v. Sevy, 129 Idaho 613 (Ct.App. 1997) (reasonable suspicion depends on particularized, external information)
State v. Zapata-Reyes, 144 Idaho 703 (Ct.App. 2007) (vehicle description too common to create reasonable suspicion)
Arizona v. Gant, 556 U.S. 332 (Sup. Ct. 2009) (vehicle search permissible if reasonable belief evidence of arrest crime is inside)
State v. Gallegos, 120 Idaho 894 (Ct. App. 1991) (automobile exception allows search with probable cause)
Texas v. Brown, 460 U.S. 730 (1983) (probable cause standard for automobile searches)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause: totality of the circumstances)
United States v. Ross, 456 U.S. 798 (1982) (scope of warrantless automobile searches)
State v. McIntee, 124 Idaho 803 (Ct. App. 1993) (search incident to arrest admissibility)
State v. Weaver, 127 Idaho 288 (Ct. 1995) (warrantless searches presumptively unreasonable; exceptions apply)