State v. Martinez-Gonzalez, 152 Idaho 775

Martinez-Gonzalez was arrested in a privately-owned apartment complex parking lot after officers observed open beer, a smell of alcohol, glazed eyes, and slurred speech; he admitted drinking and then drove toward his apartment.
Officers stopped Martinez-Gonzalez, conducted field sobriety tests, and arrested him on suspicion of DUI when he refused to participate.
A jail search revealed methamphetamine in his coat pocket, and a breath test showed a BAC of .01, below the legal limit.
The State charged one felony count of possession of a controlled substance after the DUI arrest, and did not charge DUI.
Martinez-Gonzalez moved to suppress the evidence or dismiss the information, arguing the stop/arrest lacked probable cause and failed on Fourth Amendment grounds.
The district court rejected the suppression/dismissal motions, holding there was probable cause and that the parking lot was private property open to the public.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for warrantless DUI arrest	State: officers had probable cause based on open cans, odor, slurred speech, admission, and driving behavior	Martinez-Gonzalez: no probable cause to arrest for DUI	Probable cause established; arrest lawful
Parking lot as private property open to the public	State: apartment complex parking lot is open to the public for vehicular traffic	Martinez-Gonzalez: parking is private property not open to the public	Parking lot deemed open to the public; DUI statute applies

State v. Willoughby, 147 Idaho 482 (Idaho Ct. App. 2009) (standard of review for suppression motions; credibility and factual findings retained by trial court)
State v. Fees, 140 Idaho 81 (Idaho 2004) (probable cause and suppression standards; abuse-of-discretion review in related contexts)
State v. Armbruster, 117 Idaho 19 (Ct. App. 1989) (probable cause de novo review; corroborating factors for DUI cases)
State v. Julian, 129 Idaho 133 (Idaho 1996) (probable cause standard; guidance on driving under the influence considerations)
Brinegar v. United States, 338 U.S. 160 (U.S. 1949) (probable cause concept; reasonable-person standard)
State v. Gibson, 126 Idaho 256 (Idaho 1994) (open-to-public property analysis for DUI statute; lived experience of access and intent)
State v. Knott, 132 Idaho 476 (Idaho 1999) (definitive boundary for private property open to the public under DUI statute; abrogated in part by later developments but precedent on interpretation remains)
State v. Schmitt, 144 Idaho 768 (Ct. App. 2007) (open parking lots and public access analysis for open-container/lot-access issues)
State v. Reyes, 139 Idaho 502 (Ct. App. 2003) (free review of ambiguous statutory language in DUI context; case-law-based framework)
State v. Rhode, 133 Idaho 459 (Idaho 1999) (interpretation of statute in context of open-to-public concept)