State v. KOIVU
152 Idaho 511
| Idaho | 2012Background
- Koivu was convicted of possession of methamphetamine and sentenced to prison with probation terms including fines and costs; probation was later revoked and he served time and was released in 2009.
- A Boundary County case sought payment of fines and costs by Koivu, leading to affidavits alleging nonpayment and a December 8, 2009 warrant of attachment for contempt, with no officer involvement in issuing the warrant.
- The warrant of attachment contained no attached order and set bail rather than citing a specific court order; no law enforcement officer helped generate the affidavits or issue the warrant.
- On March 5, 2010 Bonner County deputies stopped Koivu for speeding and, relying on a Boundary County warrant, arrested him; a baggie of methamphetamine was found during jail processing.
- The Bonner County district court later dismissed the warrant as jurisdictionally defective, and the State appealed; the Bonner County methamphetamine evidence was at issue in a suppression decision.
- The Idaho Supreme Court declined to overrule Guzman, applying the Leon good-faith framework only where appropriate, and upheld suppression of the methamphetamine evidence as obtained under an invalid warrant under Article I, section 17.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether State may appeal a suppression order. | State argues Rule 11(c)(7) supports appellate review. | Koivu contends no suppression motion was properly before the court. | Yes; State had a right to appeal. |
| Whether Guzman should be overruled and Leon applied to Idaho Constitution. | State argues Leon good-faith should apply and Guzman should be overruled. | Koivu argues Guzman should be retained and Leon narrowed. | Guzman not overruled; Leon good-faith not adopted for Article I, §17; evidence suppression sustained. |
Key Cases Cited
- State v. Guzman, 122 Idaho 981 (1992) (rejected applying Leon to Idaho Constitution, retroactivity discussed)
- State v. Arregui, 44 Idaho 43 (1927) (established Idaho exclusionary rule and duty to exclude unlawfully obtained evidence)
- Weeks v. United States, 232 U.S. 383 (1914) (origin of exclusionary rule by federal courts)
- Mapp v. Ohio, 367 U.S. 643 (1961) (adopted exclusionary rule as applicable to states)
- United States v. Leon, 468 U.S. 897 (1984) (Leon good-faith exception to exclusionary rule)
- Rauch v. Rauch, 99 Idaho 586 (1978) ( Weeks framework quoted; knock-and-announce context)
- Prestwich, 116 Idaho 959 (1989) (implicitly approved Leon good-faith via review-denied rule)