State v. Snapp, 414 P.3d 1199

Around midnight an officer observed Snapp speeding; the vehicle turned onto a long private driveway and did not stop for patrol lights.
While the car was still moving and in the officer's view, Snapp opened the driver-side door and tossed a dark zippered handbag toward his residence.
Officers detained and handcuffed Snapp, placed him in a patrol car, and searched the area near where the item was tossed; after 5–10 minutes they recovered the bag about a foot from the residence and three feet from the pathway.
The bag contained a large Ziploc with 119.5 grams of methamphetamine; Snapp was charged with trafficking and moved to suppress the evidence as the product of a warrantless search.
The district court denied the motion to suppress; Snapp entered a conditional guilty plea and appealed the denial.

Issue	Plaintiff's Argument (Snapp)	Defendant's Argument (State)	Held
Whether the search of the area where the bag landed intruded on curtilage and exceeded the normal access route so open-view doctrine fails	Officers unlawfully searched curtilage and departed from normal access route, so open-view not available	Officers acted within scope of search for tossed item visible from access path; search was reasonable	Not reached on merits — court found no standing due to abandonment
Whether Snapp retained a reasonable expectation of privacy in the bag (abandonment/standing)	Snapp did not abandon the bag; throwing it onto his property does not negate privacy interest	Snapp denied throwing anything and thus effectively relinquished any privacy interest by abandoning the bag	Held: Snapp abandoned the bag; he lacks standing to challenge the search
Whether the plain-view exception justified seizure/search of the bag	Plain-view does not apply because the bag’s incriminating nature was not immediately apparent	Seizure/search falls within plain-view after officer observed/took the bag while investigating tossed item	Not reached due to abandonment ruling

State v. Atkinson, 128 Idaho 559 (cites standard of review for suppression) (explaining appellate review of factual findings vs. legal application)
State v. Valdez-Molina, 127 Idaho 102 (discusses trial court's factfinding authority at suppression hearings)
State v. Schevers, 132 Idaho 786 (same; deference to trial court credibility and fact findings)
State v. Pruss, 145 Idaho 623 (articulates two-part test for expectation of privacy: subjective and societal reasonableness)
State v. Ross, 160 Idaho 757 (defines abandonment via words, acts, and objective facts)
State v. Melling, 160 Idaho 209 (disclaimer of ownership can constitute abandonment)
State v. Garcia-Rodriguez, 162 Idaho 271 (preservation rule: appellate review limited to arguments presented below)