State of Idaho, Plaintiff-Appellant v. Victor Garcia-Rodriguez, Defendant-Respondent

Summary

The Idaho Supreme Court affirmed suppression of methamphetamine discovered during a search incident to Garcia-Rodriguez's arrest. The Court held that the State could not raise for the first time on appeal its argument that probable cause constitutionally justified the arrest without regard to Idaho's statutory arrest limitations, and that the State waived its separate challenge to the district court's finding that the statutory grounds for arrest were absent because it offered no adequate argument or authority. The Court also denied rehearing, rejecting the State's factual and legal assertions concerning the governing precedent.