State v. Phillip James Morgan
154 Idaho 109
| Idaho | 2013Background
- Boise City officer observed Morgan’s SUV without a front license plate and followed it to determine license status.
- Morgan’s driving included a sequence of left turns, which the officer interpreted as either being lost or avoiding the officer.
- The SUV pulled to the right but remained on the roadway; the officer then stopped Morgan for a license-plate issue and suspected roadway obstruction.
- Morgan was arrested for DUI after field sobriety tests; he moved to suppress all stop-evidence claiming lack of reasonable suspicion.
- The district court denied suppression, ruling the officer had reasonable articulable suspicion based on Morgan’s conduct.
- On appeal, the Idaho Supreme Court reversed, vacated the conviction, and remanded for proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there reasonable suspicion for the stop? | Morgan | Morgan | No reasonable suspicion existed |
| Did Idaho Code §49-428 and §49-659 justify the stop? | Morgan | Morgan | Not justified by statute; stop invalid |
| Can Boise City Ordinance 10-11-04 be considered as a justification for the stop? | Morgan | State | Not considered; ordinance not properly before court |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (totality-of-the-circumstances standard for reasonable suspicion)
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (contextual, totality-based analysis for suspicion)
- State v. Henage, 143 Idaho 655 (Idaho 2007) (traffic stops are seizures; need reasonable suspicion)
- State v. Bishop, 146 Idaho 804 (Idaho 2009) (limits on permissible investigative detentions)
- State v. Munoz, 149 Idaho 121 (Idaho 2010) (de novo review of reasonable-suspicion determinations with totality analysis)