State v. Scott Clifford McAuley

Officer responded to report of an unresponsive person in a running car at a convenience store; found McAuley with eyes shut, head moving, and lips moving.
Officer requested medical aid, tapped the window, opened the door, and woke McAuley; medical personnel evaluated him and obtained a signed medical release.
Officer obtained McAuley’s identification and learned his driver’s license was suspended; McAuley was confused and could not account for his whereabouts or time.
After medical personnel left, officer continued questioning, asked about drugs/weapons; McAuley initially denied but then admitted there were drugs and weapons in the vehicle.
Officer removed McAuley, handcuffed him, searched the vehicle and found methamphetamine, weapons, and paraphernalia; McAuley was arrested and charged; he moved to suppress statements and evidence.
District court denied suppression, finding the seizure reasonable based on objective facts suggesting driving while suspended and possible impairment; McAuley pled guilty to possession and persistent violator and appealed.

Issue	McAuley’s Argument	State’s Argument	Held
Whether the continued detention/questioning exceeded scope of initial community-caretaking seizure and violated Fourth Amendment	Officer’s questioning about drugs/weapons was unrelated to caretaking once license suspension was confirmed; officer should have issued citation or stopped investigating	Officer had reasonable, articulable suspicion (confused behavior, impairment signs, suspended license) to expand and continue investigation	Court held detention and expanded questioning reasonable under totality of circumstances; denial of suppression affirmed
Whether statements/admissions and resulting vehicle search were fruits of unlawful detention (and whether admission supplied probable cause)	Statements and evidence should be suppressed as product of unlawful seizure	McAuley’s admission provided probable cause to arrest and legitimated search incident to arrest	Court held admission supplied probable cause; evidence admissible and suppression denial affirmed

State v. Atkinson, 128 Idaho 559 (discussing standard of review on suppression)
State v. Valdez-Molina, 127 Idaho 102 (trial court credibility determinations at suppression hearings)
State v. Schevers, 132 Idaho 786 (suppression hearing factfinding)
State v. Roe, 140 Idaho 176 (investigative detention justification and scope)
State v. Parkinson, 135 Idaho 357 (detention scope must be tailored)
State v. Sheldon, 139 Idaho 980 (specific articulable facts for investigative detention)
State v. Gutierrez, 137 Idaho 647 (temporary scope of detention)
State v. Perez-Jungo, 156 Idaho 609 (officer may pursue other suspected illegal activity upon developing reasonable suspicion)
United States v. Cortez, 449 U.S. 411 (reasonable, articulable suspicion standard)
State v. Flowers, 131 Idaho 205 (vehicle stop to investigate traffic-law violations)
State v. Ferreira, 133 Idaho 474 (totality of circumstances for reasonable suspicion)
State v. Montague, 114 Idaho 319 (officer may draw reasonable inferences from training and experience)