291 P.3d 44
Idaho Ct. App.2012Background
- Mangum was convicted by judgment of forgery of a financial transaction card after a conditional guilty plea.
- Idaho charged Mangum on related Idaho offenses after he was involved in a California detainer and IAD process.
- Mangum sent letters seeking IAD disposition; the district court held the IAD 180-day clock triggered when certificates were received, not earlier.
- The district court denied Mangum’s motions to dismiss for IAD violations and to suppress evidence from a warrantless entry.
- Mangum appeals, challenging both the IAD timing and the legality of the apartment entry observed during the search.
- The court upholds the district court’s rulings, affirming the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the IAD 180-day period started timely. | Mangum: notice was actual by August–October 2009; strict compliance not required. | Mangum contends that actual notice sufficed and the 180-day clock began earlier than December 28, 2009. | IAD requires strict compliance; 180-day limit triggered December 28, 2009. |
| Whether the search of Mangum’s apartment was valid without a warrant due to unlawful entry. | Mangum did not consent to entry beyond retrieval of ID; entry was unlawful without warrant. | Mangum implicitly consented to entry by leading officers to his apartment and retrieving his license. | There was substantial evidence of implied consent to entry for retrieving identification; denial of suppression affirmed. |
Key Cases Cited
- Alabama v. Bozeman, 533 U.S. 146 (U.S. 2001) (textual 'shall' is mandatory; strict compliance emphasized)
- Fex v. Michigan, 507 U.S. 43 (U.S. 1993) (delivery of the request must occur to trigger the 180-day clock)
- State v. Breen, 126 Idaho 305 (Ct. App. 1994) (IAD compliance criteria; detainer process and speedy trial)
- Nash v. Jeffes, 739 F.2d 878 (3d Cir. 1984) (strict compliance promotes prompt notice to authorities)
- Johnson v. Stagner, 781 F.2d 758 (9th Cir. 1986) (emphasizes procedural strictness for IAD requests)
- Copson v. Commonwealth, 830 N.E.2d 202 (Mass. 2005) (certificate forwarding is central to IAD notification)
- Greenwood v. Indiana, 665 N.E.2d 579 (Ind. 1996) (strict IAD compliance; forwarding via custodial officials required)
- Moe v. North Dakota, 581 N.W.2d 468 (N.D. 1998) (example of strict IAD compliance in practice)
- Paredes-Batista, 140 F.3d 367 (2d Cir. 1998) (IAD literal reading; strict delivery emphasized)
- Collins v. United States, 90 F.3d 1420 (9th Cir. 1996) (Fex instruction: IAD means what it says)