State v. Smith, 152 Idaho 115

Smith was convicted of trafficking marijuana in excess of one pound; suppression of backpack search was denied.
Officer encountered Smith after responding to a domestic dispute; found marijuana pipe in plain view on the front seat of Smith’s car.
Smith used a backpack to leash a growling dog; backpack remained in the car and contained a duct-taped object with marijuana.
Officer searched the backpack outside the vehicle’s interior but treated it as part of the car’s contents.
District court denied suppression, holding the search was justified either as a search incident to arrest or under the automobile exception, and Smith was convicted as charged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether backpack search was permissible as incident to arrest	Smith	Smith had no warrant and no valid incident-to-arrest basis	Yes; valid under Gant timing and Rawlings framework.
Whether the search fell within the automobile exception	State	Probable cause to search the car existed from observed paraphernalia	Yes; probable cause supported search of the vehicle and its contents.
Whether probable cause existed to justify the search	Smith	Officer had probable cause based on pipe and circumstantial cues	Yes; probable cause supported both initial search and contents.

Chimel v. California, 395 U.S. 752 (Supreme Court 1969) (describes vehicle-search/incidental-arrest principles)
Arizona v. Gant, 556 U.S. 332 (Supreme Court 2009) (limits vehicle-search incident-to-arrest to reasonable scope)
Rawlings v. Kentucky, 448 U.S. 98 (Supreme Court 1980) (pre-arrest searches may be valid if probable cause existed; timing matters)
United States v. Ross, 456 U.S. 798 (Supreme Court 1982) (automobile exception allows search of vehicle with probable cause to find contraband)
State v. Gallegos, 120 Idaho 894 (Idaho 1991) (early Idaho endorsement of automobile searches with probable cause)