Justia Construction Law Opinion Summaries

Articles Posted in Idaho Supreme Court - Criminal
Defendant-respondent Jennie Pylican moved to suppress evidence she unlawfully possessed methamphetamine and drug paraphernalia on the evening of October 12, 2017. At that time, an officer observed Pylican enter a storage facility after hours. When she left, the officer followed and observed her make a turn without signaling. Pylican was initially stopped for the traffic violation and later questioned about her presence in a storage facility after hours. The district court granted the motion, holding that the arresting officer unconstitutionally extended the stop when he questioned Pylican regarding her presence in the storage facility. In the alternative, the district court ruled that the officer unconstitutionally extended both the scope and duration of the seizure by requiring Pylican to exit her car. In an unpublished opinion, the appellate court affirmed the district court’s order granting Pylican’s motion to suppress, holding that the officer did not provide any evidence of suspicious activity at the storage facility that would justify Pylican’s extended detention on that basis. On appeal to the Idaho Supreme Court, the State argued the district court erred in grantion Pylican's motion because: (1) the deputy had reasonable suspicion to question Pylican regarding her presence in the storage facility; and (2) the deputy’s order to exit the vehicle did not unconstitutionally extend the duration of the stop. After review of the district court record, the Supreme Court reversed the district court’s order and remanded for further proceedings. View "Idaho v. Pylican" on Justia Law