Idaho v. Fuller

In 2015, Deputy Harvey Ballman was patrolling the area near the intersection of Highways 95 and 53 in Kootenai County. At approximately 10:50 p.m., Deputy Ballman observed a vehicle, driven by defendant Antonia Fuller, traveling a few car lengths in front of him. When Fuller continued on the roadway and drove her vehicle around the right-hand curve, Deputy Ballman observed the front passenger-side tire of Fuller’s vehicle drive onto and temporarily across the solid white line on the right-hand side of the roadway (i.e., the fog line). Deputy Ballman then initiated a traffic stop, citing Fuller’s failure to maintain her lane of travel as required under Idaho Code section 49-637(1). During the traffic stop, Deputy Ballman discovered that Fuller did not have a valid driver’s license or liability insurance. Fuller was arrested for violations of Idaho Code sections 49-301(1) and 49-1232 before conducting an inventory search of her vehicle. That search revealed methamphetamine, prescription drugs, and drug paraphernalia. Fuller was never cited for a traffic offense. After considering the parties’ arguments, the district court ultimately concluded Deputy Ballman did not have a reasonable, articulable suspicion that section 49-637(1) was violated. The district court thus granted Fuller’s motion to suppress. The State appealed. The Idaho Supreme Court concluded the traffic stop was unconstitutional, and affirmed the district court’s order suppressing the evidence. View "Idaho v. Fuller" on Justia Law