State v. Kyle Kent Stringham

Late afternoon on a weekday on an 80 mph interstate, an officer observed traffic averaging 80 mph; roads were dry and somewhat windy.
Officer observed an SUV in the left-hand (fast) lane traveling 68 mph and initiated a stop for allegedly violating I.C. § 49-630(2) (driving slower than the normal speed of traffic in left lane).
The driver, Kyle Stringham, displayed signs of impairment, failed field sobriety tests, was arrested, and contraband (including methamphetamine) was found after a search incident to arrest.
Stringham moved to suppress evidence, arguing the stop was an unlawful seizure because the officer lacked reasonable suspicion that he violated the statute.
The district court denied suppression; Stringham entered a conditional Alford plea to possession of methamphetamine, preserving the suppression issue for appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the traffic stop was supported by reasonable suspicion that the vehicle violated I.C. § 49-630(2) (slower-than-normal-speed vehicle in left lane)	Officer observed SUV driving 68 mph in left lane where other cars averaged 80 mph; that supported reasonable, articulable suspicion	Stringham: not surrounded by traffic; 68 mph (under speed limit) and conditions (wind, roof load) made his speed the normal speed of traffic — no statutory violation	Stop was reasonable: totality of circumstances (time, place, conditions, flow of traffic) supported suspicion of violation; suppression denied

Delaware v. Prouse, 440 U.S. 648 (stopping vehicle implicates Fourth Amendment)
United States v. Cortez, 449 U.S. 411 (reasonable suspicion assessed by totality of circumstances)
State v. Atkinson, 128 Idaho 559 (appellate standard of review for suppression rulings)
State v. Ferreira, 133 Idaho 474 (totality-of-circumstances for reasonable suspicion)
State v. Montague, 114 Idaho 319 (officer may draw reasonable inferences from experience and training)