State v. Perez, Jr., 434 P.3d 801

Around 10:30 PM a resident called dispatch reporting a white Mercedes on Wardance Circle whose driver “didn’t know how to drive,” had almost hit a parked car pulling into a driveway, had been "roaring around" and slamming brakes earlier in the day, and had earlier been observed driving "really recklessly."
Officer Henry (an Idaho Highway Safety Officer) had earlier that day noticed a white two‑door Mercedes parked on Wardance Circle and later, within approximately 10–15 minutes of the dispatch call, encountered and stopped a white Mercedes on a main road after following it for under one minute.
Henry observed no traffic violations or erratic driving while following the vehicle, but detected the smell of alcohol upon contact; an ISP officer later administered field sobriety tests and arrested Augustine Garnica Perez Jr.
Perez moved to suppress evidence from the stop, arguing the dispatch call did not supply reasonable, articulable suspicion to stop his vehicle; the district court denied the motion.
Perez entered a conditional guilty plea to felony DUI and appealed the denial of the suppression motion; the Idaho Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the citizen call provided reasonable suspicion to stop the driver for reckless driving	The State: the caller reported driving behavior (nearly hitting a parked car, earlier ‘‘roaring’’ and slamming brakes, fear of driving onto sidewalk) that reasonably suggested reckless driving	Perez: the critical conduct occurred on private property (driveway) and thus did not satisfy the reckless driving statute; tip insufficient for reasonable suspicion	Held: Tip supplied specific, articulable facts (including earlier reckless behavior) that, under the totality of circumstances, gave reasonable suspicion to investigate reckless driving
Whether the vehicle description (white Mercedes) sufficed to link Perez’s car to the report	The State: Officer Henry had seen a rare white two‑door Mercedes earlier on Wardance Circle and the caller described the same vehicle, so identification was reasonable	Perez: make and color alone are too common/indistinct to justify the stop	Held: Combined with Henry’s prior independent observation of the same car on Wardance Circle and the temporal/directional correspondence, the description supported reasonable suspicion to stop Perez

State v. Jaskowski, 163 Idaho 257, 409 P.3d 837 (discusses review standard for suppression rulings)
State v. Purdum, 147 Idaho 206, 207 P.3d 182 (governs appellate review of suppression findings)
State v. Morgan, 154 Idaho 109, 294 P.3d 1121 (reasonable suspicion determinations reviewed de novo)
State v. Bishop, 146 Idaho 804, 203 P.3d 1203 (investigatory detention standard and totality‑of‑circumstances approach)
State v. Russo, 157 Idaho 299, 336 P.3d 232 (explaining level of suspicion required for investigatory stops)
Navarette v. California, 572 U.S. 393 (unknown‑caller tips need not rule out innocent conduct; reasonable suspicion may still exist)
Arizona v. Arvizu, 534 U.S. 266 (reasonable suspicion may rest on inferences drawn from common sense and totality of circumstances)
State v. Zapata‑Reyes, 144 Idaho 703, 169 P.3d 291 (distinguishable precedent on insufficiency of a generalized vehicle description)