Idaho v. Hoskins

Justin Hoskins appealed a district court’s denial of his motion to suppress. In September 2016, Idaho State Trooper Spencer Knudsen observed a Pontiac Grand Am driving with a cracked windshield and pulled it over. He asked the driver for the vehicle’s registration and insurance as well as identification for the vehicle’s three occupants. The identification revealed that Jovette Archuleta was the driver of the vehicle, Amber Alvarez was seated in the passenger’s seat, and Hoskins was seated alone in the back seat. dispatch informed Trooper Knudsen that the vehicle’s license plates actually belonged to a Chevrolet Malibu registered to Archuleta. Dispatch also notified Trooper Knudsen that all of the vehicles’ occupants had prior drug convictions. Returning to the Pontiac, Trooper Knudsen asked Archuleta to step out of the car to speak with him. Once she had, he questioned her about whether the car contained anything illegal. After she stated that she didn’t believe so, Trooper Knudsen asked for permission to search the car. Alvarez gave her permission to search the vehicle. Before searching the vehicle, Trooper Knudsen directed Hoskins to get out of the backseat, instructing Hoskins to leave his personal items on the backseat. During the search, Trooper Knudsen found marijuana and methamphetamine. Hoskins was arrested and charged with possession of methamphetamine with a sentencing enhancement based on a prior drug conviction. Hoskins promptly filed a motion to suppress the evidence taken from the traffic stop. The State argued Hoskins lacked standing to object to the search based on consent and the district court denied the motion on that basis. On appeal, all parties agreed the district court’s ruling on standing was erroneous. Nevertheless, the State argued the district court’s decision could be affirmed based on the plain-view doctrine. Hoskins objected and argued the State forfeited this argument by failing to raise it below. Hoskins prevailed at the Court of Appeals and the Idaho Supreme Court granted the State’s timely petition for review. The Supreme Court did not consider the State's plain-view argument on appeal because the issue was not preserved for review: "Devising a 'correct' theory for the first time on appeal does not give the State a legal mulligan when it concedes that its original theory did not carry the burden below. The same logic holds true for the State’s argument regarding exceptions to the exclusionary rule." The Court reversed the district court's denial of Hoskins' motion to suppress, vacated his judgment of conviction and remanded the matter for further proceedings. View "Idaho v. Hoskins" on Justia Law