State v. Wayne Ray Floyd
159 Idaho 370
| Idaho Ct. App. | 2015Background
- Police approached Floyd and a companion at night; both appeared under the influence of marijuana and admitted smoking at Floyd’s nearby home.
- An officer told Floyd he would not arrest him for being an intoxicated pedestrian if Floyd would accompany officers to his home to retrieve and dispose of marijuana paraphernalia; Floyd agreed.
- Floyd led officers to his residence; three officers entered and Floyd directed them to his paraphernalia and then consented to a search of his bedroom.
- The subsequent search uncovered methamphetamine and paraphernalia; Floyd was charged with possession of a controlled substance and manufacturing with intent to deliver paraphernalia.
- Floyd moved to suppress, arguing his consent to entry/search was coerced; the district court denied the motion, he pled guilty while preserving the suppression issue, and appealed.
- The appellate court reviewed the record for substantial evidence supporting the district court’s implicit finding that consent was voluntary and affirmed the denial of suppression.
Issues
| Issue | Floyd's Argument | State's Argument | Held |
|---|---|---|---|
| Whether Floyd’s consent to police entry/search was voluntary or the product of coercion | Consent was coerced by officers’ presence, visible weapons, and the officer’s promise not to arrest unless Floyd cooperated | Officer’s promise was an informational offer within authority; record shows no confrontation, threats, or uncooperativeness; consent was voluntary | Court affirmed: substantial evidence supports implicit finding that consent was voluntary and not coerced |
Key Cases Cited
- State v. Garcia, 143 Idaho 774 (Ct. App.) (officer’s offer not to arrest in exchange for turning over drugs is not per se coercive)
- Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (voluntariness of consent judged from totality of circumstances)
- State v. Kirkwood, 111 Idaho 623 (1986) (appellate courts may infer implicit trial-court findings from the record when written findings were not requested)
- State v. Rector, 144 Idaho 643 (Ct. App.) (suppression affirmed where coercive circumstances supported trial court’s finding)
- State v. Atkinson, 128 Idaho 559 (Ct. App.) (standard of review for suppression: accept trial court’s factual findings supported by substantial evidence)