State v. Natasha Lynn Bly, 366 P.3d 193

Nampa police were surveilling a motel in a high drug-crime area after reports of drug activity; an officer ran plates on a car registered to a male with an active drug-related warrant.
The officer observed three women briefly enter the hotel and leave; he believed their conduct was consistent with a drug transaction but saw no interaction between them and Bly.
Bly exited the hotel, got into and out of the watched car several times, drove it across the lot, reentered the hotel, then came back out. The officer told her to “hold on a minute,” which the court treated as an investigative detention.
During the encounter the officer detected burnt marijuana odor, bloodshot eyes, slurred speech, and blisters on Bly’s tongue; Bly was detained and, during a search incident to arrest, methamphetamine was found.
Bly moved to suppress the evidence; the district court denied the motion as the detention was reasonable. Bly entered a conditional guilty plea reserving the suppression issue. The Court of Appeals vacated the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the officer had reasonable, articulable suspicion to justify an investigative detention when he told Bly to “hold on a minute.”	Totality of circumstances (high-crime area; observed activity consistent with drug transactions; Bly accessed a car registered to a person with a drug warrant; her repeated entry/exit and relocating the car were suspicious).	Those facts do not particularize suspicion to Bly: presence in a high-crime area, proximity to others, use of a car registered to a male with a warrant, and lawful but odd conduct are insufficient without articulable facts linking Bly to criminal activity.	Held for Bly: the totality of facts did not produce reasonable suspicion particularized to her; detention was unjustified, so evidence should have been suppressed.

Wong Sun v. United States, 371 U.S. 471 (exclusionary rule for evidence from unreasonable searches/seizures)
Florida v. Royer, 460 U.S. 491 (distinguishes standard for seizures and allows limited investigative detentions on reasonable suspicion)
Terry v. Ohio, 392 U.S. 1 (authorizes investigative stops on reasonable articulable suspicion)
United States v. Cortez, 449 U.S. 411 (totality-of-circumstances test for reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (presence in high-crime area alone insufficient for reasonable suspicion)
Ybarra v. Illinois, 444 U.S. 85 (mere proximity to suspected persons insufficient to justify suspicion of third parties)
United States v. Sokolow, 490 U.S. 1 (innocent acts can collectively justify reasonable suspicion under the totality of the circumstances)
State v. Pike, 551 N.W.2d 919 (Minn. Ct. App.) (officer may presume driver is vehicle owner only absent facts undermining that inference)
State v. Holcomb, 128 Idaho 296, 912 P.2d 664 (Idaho Ct. App.) (contrast case where observed conduct supported reasonable suspicion)
State v. Crooks, 150 Idaho 117, 244 P.3d 261 (Idaho Ct. App.) (reasonable suspicion where defendant was located at a specific site known for drug transactions)