State v. Randall, 496 P.3d 844

Background

Idaho State Police stopped Jacob Randall for a lane-change/signal violation; during the stop the officer developed suspicion of drug trafficking based on travel itinerary, nervousness, and a "lived-in" vehicle appearance.
Randall consented to an exterior K-9 sniff; officer deployed K-9 Bingo from his patrol car to conduct the sniff.
Bingo immediately leapt into the open driver-side window (handler gave a brief boost to avoid injury), remained inside ~16–21 seconds, and the handler testified Bingo alerted in the back seat; Bingo then alerted on the trunk as well.
Following the alerts, officers conducted a warrantless search and found ~65 pounds of marijuana; Randall was charged with drug trafficking and moved to suppress.
The district court denied suppression, relying on State v. Naranjo (a drug dog’s "instinctive" entry is not a Fourth Amendment search); the Idaho Supreme Court affirmed that the prolongation of the stop was supported by reasonable suspicion but reversed suppression because the dog’s trespass into the vehicle was a warrantless search under the Fourth Amendment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Was the traffic stop unconstitutionally prolonged by a K-9 sniff?	State: Officer developed reasonable suspicion during the stop to expand investigation.	Randall: Nervousness and travel plans alone did not supply reasonable suspicion (relying on Kelley).	Held: No unlawful prolongation; totality of circumstances gave reasonable suspicion to detain for a sniff.
2) Did the dog’s leap into the car constitute a Fourth Amendment search?	State: The dog acted "instinctively" on its own, so no officer trespass/search (Naranjo rule).	Randall: Jones/Jardines require that a physical trespass by a government tool/agent to obtain information is a search; dog entry was a trespass/search without warrant or probable cause.	Held: Dog’s entry into the car was a trespass-for-information and therefore a warrantless search that violated the Fourth Amendment.
3) Could the State rely on the post-entry exterior alert (inevitable discovery/attenuation) to avoid suppression?	State: Bingo later alerted on the trunk so interior alert was not the but-for cause of discovery.	Randall: Suppression required because initial interior trespass/search was unconstitutional.	Held: State’s inevitable-discovery/attenuation argument was not preserved below and is waived.
4) Remedy—Should evidence be suppressed?	State: Evidence should not be suppressed because no search or because later exterior alert validated the search.	Randall: Exclusion required because seizure followed an unconstitutional search.	Held: Court reversed denial of suppression and vacated conviction; exclusion applied (no exception established).

Key Cases Cited

United States v. Jones, 565 U.S. 400 (2012) (a physical trespass onto property for the purpose of obtaining information is a Fourth Amendment search)
Florida v. Jardines, 569 U.S. 1 (2013) (bringing a drug dog onto curtilage and obtaining information by physical intrusion is a search despite Caballes)
Illinois v. Caballes, 543 U.S. 405 (2005) (an exterior canine sniff during a lawful traffic stop is generally not a Fourth Amendment search because it reveals only presence of contraband)
Kyllo v. United States, 533 U.S. 27 (2001) (use of sense-enhancing technology to obtain information about the interior of a protected area can be a search)
Rodriguez v. United States, 575 U.S. 348 (2015) (authority for a traffic stop ends when tasks tied to the traffic infraction are reasonably completed)
Terry v. Ohio, 392 U.S. 1 (1968) (investigative stops must be based on specific, articulable facts and be reasonable in scope)
United States v. Cortez, 449 U.S. 411 (1981) (reasonable suspicion evaluated under the totality of the circumstances)
State v. Naranjo, 159 Idaho 258, 359 P.3d 1055 (Idaho Ct. App. 2015) (held a dog’s "instinctive" independent entry did not constitute a Fourth Amendment search)
State v. Kelley, 160 Idaho 761, 379 P.3d 351 (Idaho Ct. App. 2016) (discussed limits of nervousness and travel plans as reasonable suspicion)
State v. Anderson, 154 Idaho 703, 302 P.3d 328 (2012) (reliable exterior dog alert can establish probable cause for automobile search)