569 P.3d 137
Idaho2025Background
- Chadlen Dewayne Smith was arrested after a series of encounters with a police dispatcher, which began with Smith following her home and later appearing near her residence on multiple occasions.
- He was arrested for misdemeanor stalking in the second degree, leading to the seizure of his electronic devices.
- Following the arrest, police impounded Smith’s vehicle and conducted an inventory search, seizing additional electronic devices.
- Searches of Smith’s devices uncovered sexually exploitative materials; Smith was ultimately convicted of felony sexual exploitation of a child based on this evidence.
- Smith challenged the district court’s denial of his motion to suppress the evidence from his vehicle, asserting that the impoundment and inventory search were unconstitutional.
Issues
| Issue | Smith's Argument | State's Argument | Held |
|---|---|---|---|
| Probable Cause for Stalking Arrest | Arrest lacked probable cause; not enough nonconsensual contact, and conduct not in officer’s presence | Smith’s repeated presence and conduct created reasonable suspicion of stalking | Arrest was based on probable cause; upheld by court |
| Warrantless Arrest for Misdemeanor Not in Presence | Arrest unconstitutional because not committed in officer’s presence | Smith’s conduct (following and appearing near victim’s home) occurred in officer’s presence | Court found arrest lawful under Idaho law |
| Impoundment and Inventory Search of Vehicle | Impoundment unreasonable, pretext for warrantless search, no community caretaking purpose | Impoundment and search followed department policy, justified by Smith’s arrest | Impoundment not justified; lacked community caretaking purpose, search unconstitutional |
| Admissibility of Evidence from Vehicle Search | All resulting evidence should be suppressed as fruit of unlawful search | Evidence admissible; inventory search exception applies | Evidence ruled inadmissible; conviction vacated |
Key Cases Cited
- South Dakota v. Opperman, 428 U.S. 364 (inventory search of impounded vehicles as community caretaking function)
- Illinois v. Gates, 462 U.S. 213 (totality of circumstances standard for probable cause)
- Wong Sun v. United States, 371 U.S. 471 (fruits of unconstitutional searches and exclusionary rule apply)
- State v. Weber, 116 Idaho 449 (probable cause for arrest; objective totality of circumstances)
- State v. Eliasen, 158 Idaho 542 (definition of stalking course of conduct and nonconsensual contact)
- State v. Weaver, 127 Idaho 288 (requirements for inventory search and impoundment reasonableness under Fourth Amendment)