State v. Wheeler, 48043

In Sept. 2019 Wheeler’s sister told dispatch Wheeler lived at a Twin Falls residence and had an outstanding arrest warrant; officers confirmed an active warrant and Wheeler’s address from her driver’s license.
Officers arrived; a woman coming from the residence (Wheeler’s sister) told officers Wheeler was inside.
Officers entered, located and arrested Wheeler; marijuana was in plain view on a table and, on arrest, officers searched Wheeler’s purse (on her person) and found methamphetamine and drug paraphernalia.
Wheeler moved to suppress all evidence seized during the arrest; the district court denied suppression, finding entry justified by the arrest warrant (reasonable belief Wheeler was inside) and alternatively by consent based on the sister’s apparent authority.
Wheeler conditionally pled guilty, reserved the right to appeal the suppression denial, and the Court of Appeals affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Wheeler)	Held
Lawful entry to execute arrest warrant	Officers had a reasonable belief Wheeler was inside (address on driver’s license + person from house confirmed presence)	Entry was unlawful; motion to suppress should have been granted	Entry was lawful under Payton—officers had reason to believe suspect was inside, so entry to execute warrant permitted
Admissibility of items found in plain view and in purse	Items were lawfully seized following a valid arrest and plain-view observation	Seizures/searches were tainted by unlawful entry and should be suppressed	Evidence admissible because entry and subsequent arrest/search were lawful
Validity of alternative consent ruling	Sister had apparent authority to consent to entry	Wheeler did not challenge the district court’s alternative consent ruling on appeal	Affirmed on the unchallenged alternative ground; appellate court must affirm if one uncontested basis supports the ruling (Rich principle)

Payton v. New York, 445 U.S. 573 (1980) (arrest warrant implicitly permits limited entry into suspect’s dwelling when there is reason to believe the suspect is inside)
State v. Curl, 125 Idaho 224 (1993) (warrantless residential entry presumptively prohibited under Fourth Amendment)
State v. Northover, 133 Idaho 655 (Ct. App. 1999) (officer may enter a suspect’s house to execute an arrest warrant when officer has reason to believe suspect is inside)
Rich v. State, 159 Idaho 553 (2015) (appellate court affirms on an alternative, unchallenged ground)