State v. Smith, 569 P.3d 137

Chadlen Dewayne Smith was arrested following stalking allegations involving a police dispatcher in Post Falls, Idaho, after repeated concerning behavior near her home.
Upon arrest, police seized Smith’s electronic devices and, after detecting exploitative material, later impounded his car and conducted an inventory search yielding additional evidence.
Smith was charged with felony sexual exploitation of a child and misdemeanor distribution of obscene material, but challenged the evidence as the product of an unlawful search and seizure.
The district court denied Smith’s motion to suppress, reasoning the arrest and vehicle impoundment were lawful and the search followed police protocol.
On appeal, the Idaho Supreme Court focused solely on whether the motion to suppress evidence from the vehicle should have been granted, as it was dispositive.

Issue	Smith’s Argument	State’s Argument	Held
Probable cause for stalking arrest	No probable cause; actions were innocent	Probable cause existed based on pattern of conduct	Probable cause supported arrest and initial phone seizure
Constitutionality of warrantless arrest for misdemeanor	Arrested without warrant for conduct not in presence	Arrest was for conduct in officer’s presence	Arrest valid as conduct occurred in officer’s presence
Lawfulness of vehicle impoundment and inventory search	Impoundment lacked community caretaking justification	Impoundment followed standard procedure post-arrest	Impoundment lacked community caretaking purpose, so was unlawful
Admissibility of evidence found in impound search	Evidence is “fruit of the poisonous tree” and must be suppressed	Evidence lawfully obtained via inventory exception	All evidence from the inventory search must be suppressed

State v. Ramos, 536 P.3d 876 (Idaho 2023) (impoundment of vehicle must serve community caretaking purpose; investigation pretext renders impoundment unreasonable)
South Dakota v. Opperman, 428 U.S. 364 (1976) (inventory search exception to warrant requirement, but only after lawful impoundment)
State v. Weaver, 900 P.2d 196 (Idaho 1995) (inventory searches must adhere to standard procedures and lawful impoundment)
Wong Sun v. United States, 371 U.S. 471 (1963) (fruit of the poisonous tree doctrine excludes derivatively obtained evidence)