State v. Martin Guzman Ambriz
Background
- Officers observed Martin Guzman Ambriz make a left turn onto E. 16th Street during which the passenger-side tires entered gravel at the right edge of the roadway; officers followed him and then observed a proper right turn during which the car made quick, jerky side-to-side motions within its lane.
- Officers initiated a traffic stop based on the gravel excursion and the jerking movements; dash camera began recording after the gravel event.
- After contact, officers detected signs of impairment; Ambriz failed field sobriety tests and registered breathalyzer readings of .209 and .195.
- Ambriz—previously convicted for DUI—was charged with felony DUI and moved to suppress evidence from the stop, arguing lack of reasonable suspicion for either a traffic violation or DUI.
- The district court denied the motion to suppress, finding the driving pattern was outside the broad range of normal driving behavior and provided reasonable suspicion of a traffic violation or other criminal activity.
- Ambriz conditionally pleaded guilty, preserving the suppression issue for appeal; the Court of Appeals reviewed whether the stop was supported by reasonable suspicion of a traffic violation or DUI.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Ambriz) | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to stop for a traffic violation (I.C. §§ 49-630(1), 49-637(1)) | Stop was justified because Ambriz drove into gravel (tires left roadway), implicating lane/right-side rules | Driving into gravel and jerky movements are within normal driving variations and did not violate a specific statute; State didn’t raise specific statutes below | Court: District court made insufficient fact findings to show statutory violation; State may not raise those specific statutes for first time on appeal |
| Whether officers had reasonable suspicion to stop for DUI | Officers observed driving into gravel plus immediate jerking within lane — collectively created reasonable suspicion of impairment | The observed conduct individually falls within normal driving behavior and does not support reasonable suspicion of DUI | Court: Under the totality of circumstances (gravel excursion + jerking), officers had reasonable, articulable suspicion to stop for DUI |
| Preservation of argument on appeal (State raising traffic-statute theory first on appeal) | N/A — State attempted to justify stop on statutory violation on appeal | State’s traffic-statute theory was not argued below; appellate review limited to theories presented to district court | Court: State cannot assert new statutory-violation theory on appeal; district court lacked opportunity to evaluate those statutes |
| Sufficiency of district-court factual findings to review claimed traffic violation | N/A | District court’s findings described driving behavior but did not identify statutory elements (e.g., lane markings, roadway width) | Court: Findings were insufficient to determine whether elements of I.C. §§ 49-630(1) or 49-637(1) were met |
Key Cases Cited
- State v. Emory, 119 Idaho 661 (Ct. App.) (facts that can be explained as normal driving do not support reasonable suspicion of DUI)
- State v. Atkinson, 128 Idaho 559 (Ct. App.) (repeated lane-touching/weaving outside normal driving supports reasonable suspicion of impairment)
- State v. Neal, 159 Idaho 439 (Ct. App.) (single jerky movements alone insufficient for DUI reasonable suspicion)
- State v. Armstrong, 158 Idaho 364 (Ct. App.) (appellate courts may not affirm based on arguments not raised below)
- State v. Diaz, 158 Idaho 629 (Ct. App.) (correct rulings may be sustained on proper legal theory even if district court relied on incorrect rationale)