## Facts

- Randy Paul Koivu was convicted in 2004 of methamphetamine possession and received a suspended prison sentence with four years’ probation, including monetary payment conditions (fine, costs, fees, restitution).
- In 2005, after probation violations, the district court revoked probation and committed Koivu to the Idaho Board of Correction.
- After Koivu’s release from prison in 2009, a deputy court clerk filed affidavits asserting unpaid monetary obligations and noncompliance with a payment order tied to the earlier case.
- In December 2009, the district court issued a warrant of attachment directing Koivu’s seizure to appear and show cause for contempt for failure to comply with “that certain order of the Court,” but no order was attached; bail was set in the amount required to purge the contempt.
- Law enforcement officers and the prosecutor were not involved in generating the clerk affidavits or issuing the warrant.
- In March 2010, during a lawful traffic stop in Bonner County, deputies learned of the outstanding warrant, arrested Koivu, and during booking discovered methamphetamine near his feet.
- Koivu was charged with methamphetamine possession (with a persistent violator enhancement).
- The district court later concluded the warrant had been wrongly issued because the payment obligations were probation conditions that ceased to provide a basis for contempt after probation was revoked; it suppressed the methamphetamine under Article I, section 17 of the Idaho Constitution.
- The State appealed, asking the Idaho Supreme Court to overrule State v. Guzman and adopt the federal United States v. Leon good-faith exception for Idaho constitutional search-and-seizure violations.

## Issues

1. Whether the Idaho Supreme Court should overrule State v. Guzman and adopt the Leon good-faith exception to the exclusionary rule for violations of Article I, section 17 of the Idaho Constitution.
2. If Leon does not apply under Idaho’s Constitution, whether evidence found incident to an arrest on a warrant later determined to have been wrongly issued must be suppressed.

## Decision

- The Idaho Supreme Court affirmed the suppression order.
- The court declined to overrule State v. Guzman and reaffirmed that Idaho does not apply Leon’s good-faith exception to Article I, section 17 violations.
- Because Koivu’s arrest was based on a warrant determined to have been wrongly issued, the evidence discovered incident to that arrest was inadmissible under Idaho’s exclusionary rule.

## Legal Principles

- Under Article I, section 17 of the Idaho Constitution, Idaho’s exclusionary rule operates as a state constitutional remedy and is not limited to deterring police misconduct.
- Idaho rejects the federal Leon good-faith exception for state constitutional search-and-seizure violations; reasonable reliance by officers on a warrant does not, by itself, permit admission of unlawfully obtained evidence under state law.
- Stare decisis governs state constitutional interpretation; a party seeking to overturn controlling precedent bears the burden to show a sufficient justification, and a policy-based preference for Leon is insufficient absent grounds to depart from prior constitutional construction.
- When an arrest lacks valid legal authority under Article I, section 17, evidence obtained as a result of that arrest is subject to suppression unless a recognized Idaho exception applies.

## Conclusion

The Idaho Supreme Court held that evidence discovered incident to Koivu’s arrest on a warrant later determined to have been wrongly issued was properly suppressed under Article I, section 17, and it reaffirmed that Idaho’s Constitution does not recognize the Leon good-faith exception, leaving State v. Guzman intact.


State v. Koivu, 272 P.3d 483 (Idaho 2012)