State v. Lancaster, 519 P.3d 1176

Over a month in spring 2019 three ATMs were stolen in Boise; security footage tied the suspect to an Enterprise rental car rented to Clarence Lancaster.
Officers located a vehicle matching the description; when approached Lancaster gave a false name, was handcuffed, and escorted to a patrol car and then to the police station. Officers repeatedly said detectives wanted to talk to him but did not tell him the cause of the arrest.
At the station, after Miranda warnings, Lancaster confessed to stealing the three ATMs and led police to the recovered machines; additional campus burglary allegations were added later but he did not confess to those.
Lancaster moved to suppress the confession and results of the arrest under Idaho Code § 19-608 (failure to inform arrestee of cause), arguing the statutory violation made the seizure unconstitutional under Article I, § 17 of the Idaho Constitution. The district court found a § 19-608 violation but held it did not rise to a constitutional violation and denied suppression.
At sentencing Lancaster objected to a 2009 Utah PSI attached to the Idaho PSI; the court reviewed and redlined some items, adopted a 2015 federal PSI as authoritative for criminal history, and declined to strike the Utah PSI.
Lancaster appealed; the Idaho Supreme Court affirmed both the denial of suppression and the district court’s handling of the PSI attachments.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Lancaster)	Held
Whether failure to inform arrestee of the cause of arrest under I.C. § 19-608 creates a constitutional violation requiring suppression under Idaho Const. art. I, § 17	§19-608 noncompliance is a statutory error only; it does not convert the seizure into a constitutional violation or justify suppression	The officers’ failure to tell him the cause of arrest rendered the seizure unreasonable under article I, § 17 and evidence obtained thereafter must be suppressed	Affirmed: statutory notice violation found, but it did not rise to a constitutional violation warranting suppression (Sutterfield controls)
Whether the district court abused its discretion by refusing to strike a 2009 Utah PSI attached to the Idaho PSI	The court properly exercised discretion: PSI rules allow hearsay, court must reject only inaccurate or unreliable items and may rely on more authoritative records; it used the 2015 federal PSI as authoritative and redlined corrections	The Utah PSI contained inaccurate/conflicting and prejudicial information and should have been stricken	Affirmed: no abuse of discretion; court redlined corrections, relied on the federal PSI for criminal history, and followed PSI procedures

State v. Sutterfield, 168 Idaho 558, 484 P.3d 839 (holding failure to satisfy §19-608’s notice requirement did not, by itself, require suppression)
State v. Clarke, 165 Idaho 393, 446 P.3d 451 (framework for interpreting Idaho Const. art. I, § 17 and use of pre-constitutional statutes/common law as informative but not incorporated)
State v. Rauch, 99 Idaho 586, 586 P.2d 671 (knock-and-announce violations can implicate article I, § 17 and warrant exclusion)
State v. Green, 158 Idaho 884, 354 P.3d 446 (suppression is a court-created remedy and should not be extended to mere statutory violations)
State v. Guzman, 122 Idaho 981, 842 P.2d 660 (discussion of Idaho’s independent exclusionary rule and its purposes)
State v. Hanchey, 169 Idaho 635, 500 P.3d 1159 (standards for striking information from a PSI and requirement to redline unreliable material)