State v. Jose Perez-Jungo
156 Idaho 609
Idaho Ct. App.2014Background
- Perez-Jungo was convicted of possession of methamphetamine and challenged a suppression ruling on extended detention during an investigatory stop.
- An officer found Perez-Jungo's vehicle parked on a rural gravel road at about 1:36 a.m. and activated emergency lights to approach.
- Initial justifications for the stop included possible abandonment, theft, assistance needs, or nearby vandalism; these concerns were dispelled after contact.
- The officer learned the vehicle was not stolen, the driver was not in need of assistance, and Perez-Jungo had valid license information via a status check; backup and a canine unit were requested.
- During questioning, officers observed drug paraphernalia and a controlled substance, leading to arrest; Miranda warnings issue was separated from the suppression ruling; Perez-Jungo later pled guilty to possession of methamphetamine.
- The district court denied suppression for the extended detention but granted suppression related to Miranda; on appeal, Perez-Jungo challenges the detention extension and its scope.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the detention legally extended on reasonable suspicion? | Perez-Jungo | Perez-Jungo | Yes; reasonable suspicion supported extension. |
| Was the scope of the extended detention reasonably related to the suspicion? | Perez-Jungo | Perez-Jungo | Yes; scope reasonably tailored to investigation of drug activity. |
| Did custodial interrogation occur before Miranda advisement? | State argued Miranda issue separate | Perez-Jungo | Miranda issue resolved in favor of suppression? |
| Did the officer need to pursue field sobriety tests to be least intrusive means? | Perez-Jungo | Perez-Jungo | No; detention length controls reasonableness; alternatives permissible. |
Key Cases Cited
- United States v. Cortez, 449 U.S. 411 (1981) (reasonable suspicion based on totality of circumstances)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (location and time factors in reasonable suspicion analysis)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality of circumstances standard for suspicion)
- State v. Brumfield, 136 Idaho 913 (2001) (extension of detention supported by multiple suspicious factors)
- State v. Grigg, 149 Idaho 361 (2010) (bloodshot/glassy eyes as factor in suspicious circumstances)
- State v. Roe, 140 Idaho 176 (2004) (reasonable scope of detention and encounter during stop)