Tarango Deforest Padilla v. State, 161 Idaho 624

Padilla was convicted of two counts of grand theft and sentenced as a persistent violator; his direct appeal was affirmed. He then filed a timely petition for post‑conviction relief claiming ineffective assistance of trial counsel for failing to move to suppress evidence.
At ~2:00 a.m. an officer in a marked car pulled up to an alley, turned on headlights, and began to exit; Padilla fled, ran between houses, jumped a fence, twisted his ankle and fell into bushes.
While Padilla lay in the bushes he discarded items, later recovered by officers: a credit card belonging to Mauch, cash, and pieces of a spark plug; officers also found additional credit cards and spark plug pieces on Padilla during a search after he was handcuffed.
Padilla’s post‑conviction petition asserted counsel was ineffective for not moving to suppress the tangible evidence as the product of an unlawful seizure.
The district court denied relief, the Court of Appeals remanded for additional findings, the district court again denied relief, the Court of Appeals affirmed, and the Idaho Supreme Court granted review and heard the case anew.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Was counsel ineffective for failing to move to suppress the tangible evidence?	Padilla: counsel erred by not filing a suppression motion; evidence should have been suppressed.	State: any suppression motion would have failed because seizure and searches were lawful.	Held: No ineffective assistance — a suppression motion would not have succeeded.
2) Was Padilla "seized" before he discarded the items (making the discards fruit of an unlawful seizure)?	Padilla: his lying in the bushes after injury amounted to submission to police authority, so items discarded thereafter flowed from seizure.	State: seizure did not occur until handcuffing; Padilla did not submit or signal surrender; items on ground were in open view and recoverable.	Held: Seizure occurred at handcuffing; Padilla did not submit while hiding; items on ground were lawfully observed/recovered.
3) Was flight sufficient to justify investigative stop and search?	Padilla: he claimed he did not know the vehicle was police and ran to avoid being jumped, so flight should not support suspicion.	State: objective totality of circumstances (marked car illuminated and positioned; Padilla fled over fence at 2 a.m.) gave reasonable, articulable suspicion.	Held: Flight plus circumstances justified investigatory stop; officers had reasonable suspicion.