State v. Warren

Summary

The Idaho Supreme Court reversed an order suppressing evidence obtained after officers stopped a vehicle for registration violations and investigated whether the driver was violating a criminal no-contact order involving the passenger. The majority held that officers could continue detaining the passenger while controlling the scene and investigating the driver's suspected criminal conduct. A concurrence agreed that the passenger's detention was lawful but stated that a search of the passenger and her belongings would require individualized reasonable suspicion, an issue not preserved on appeal.

Holdings

1. When a lawful traffic stop gives rise to reasonable suspicion that the driver is committing another, potentially more serious crime, officers may continue controlling the scene and detaining the vehicle's passengers while investigating that crime; the passenger's detention does not become unlawful merely because officers abandoned the original traffic-related purpose.

Questions Presented

1. Whether officers may continue detaining a passenger during a traffic stop when the investigation shifts to a potentially more serious crime by the driver and officers have reasonable suspicion that the driver is violating a protection or no-contact order.
2. Whether the district court erred in suppressing evidence obtained after officers abandoned the original traffic-stop purpose.

Disposition

reversed