State v. Dozal

CourtIdaho Court of Appeals
DecidedApril 7, 2026
Docket52586
StatusUnpublished

This text of State v. Dozal (State v. Dozal) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Dozal, (Idaho Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 52586

STATE OF IDAHO, ) ) Filed: April 7, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED JESUS OMAR DOZAL, JR., ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the Third Judicial District, State of Idaho, Canyon County. Hon. Matthew J. Roker, District Judge. Hon. Thomas A. Sullivan, Magistrate.

Decision of the district court, on intermediate appeal from the magistrate court, affirming judgment of conviction for resisting or obstructing a peace officer, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Andrea W. Reynolds, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Neil Paterson, Deputy Attorney General, Boise, for respondent. ________________________________________________

LORELLO, Judge Jesus Omar Dozal, Jr., appeals from the decision of the district court, on intermediate appeal from the magistrate court, affirming his judgment of conviction for resisting or obstructing a peace officer. We affirm. I. FACTUAL AND PROCEDURAL BACKGROUND An officer initiated a traffic stop after observing a nonfunctioning headlight on Dozal’s vehicle. The officer requested Dozal’s driver’s license, vehicle registration, and proof of insurance. Initially, Dozal did not comply with the officer’s requests and questioned the basis for

1 the stop. Dozal ultimately provided his driver’s license and proof of insurance but was unable to locate his vehicle registration. While Dozal searched for the registration, the officer radioed dispatch and asked whether a canine unit officer was available to assist with the stop. Thereafter, the officer returned to Dozal’s vehicle and asked if he had given up looking for the registration. Dozal indicated he had not given up and continued searching. The officer returned to his patrol vehicle and began preparing a citation for the nonfunctioning headlight. After confirming with Dozal that he had not located the registration, the officer again returned to his vehicle to add a second citation for failure to carry proof of registration. While the officer was completing the citations, a canine unit officer arrived at the scene with a drug dog and deployed the dog to perform a drug-detection sniff of the vehicle. Ultimately, the drug dog alerted to the presence of narcotics in Dozal’s vehicle. The officer informed Dozal that the drug dog alerted and requested that Dozal exit the vehicle. Dozal refused. After multiple commands, officers removed Dozal from the vehicle and took him into custody. A subsequent search of the vehicle yielded no illegal substances. The State charged Dozal with resisting or obstructing a peace officer. Dozal filed a motion to suppress, arguing the officer unlawfully extended the traffic stop by delaying the citation process to allow time for the canine unit officer to arrive and conduct the drug-detection sniff. The magistrate court denied the motion, finding the officer’s testimony credible and concluding any delay was not caused by the request for a canine unit officer. Following a jury trial, Dozal was found guilty of resisting or obstructing a peace officer. I.C. § 18-705. Dozal appealed to the district court, arguing the magistrate court erred in denying his motion to suppress because the stop was unlawfully extended. The district court affirmed, and Dozal again appeals. II. STANDARD OF REVIEW For an appeal from the district court, sitting in its appellate capacity over a case from the magistrate court, we review the record to determine whether there is substantial and competent evidence to support the magistrate court’s findings of fact and whether the magistrate court’s conclusions of law follow from those findings. State v. Korn, 148 Idaho 413, 415, 224 P.3d 480, 482 (2009). However, as a matter of appellate procedure, our disposition of the appeal will affirm or reverse the decision of the district court. State v. Trusdall, 155 Idaho 965, 968, 318 P.3d 955,

2 958 (Ct. App. 2014). Thus, we review the magistrate court’s findings and conclusions, whether the district court affirmed or reversed the magistrate court and the basis therefor, and either affirm or reverse the district court. III. ANALYSIS “Mindful of” State v. Pylican, 167 Idaho 745, 477 P.3d 180 (2020), Dozal argues the district court erred in affirming the magistrate court’s denial of his motion to suppress because the traffic stop was unlawfully extended when the “officer delayed writing a citation to permit a drug dog to sniff the exterior of his vehicle.” The State responds that the district court was correct in affirming the magistrate court because any delay in completing the traffic stop was caused by Dozal’s own conduct. We hold that Dozal has failed to show the district court erred in affirming the magistrate court’s denial of his motion to suppress. A traffic stop by an officer constitutes a seizure of the vehicle’s occupants and implicates the Fourth Amendment’s prohibition against unreasonable searches and seizures. Delaware v. Prouse, 440 U.S. 648, 653 (1979); State v. Atkinson, 128 Idaho 559, 561, 916 P.2d 1284, 1286 (Ct. App. 1996). Under the Fourth Amendment, an officer may stop a vehicle to investigate possible criminal behavior if there is a reasonable and articulable suspicion that the vehicle is being driven contrary to traffic laws. United States v. Cortez, 449 U.S. 411, 417 (1981); State v. Flowers, 131 Idaho 205, 208, 953 P.2d 645, 648 (Ct. App. 1998). In the traffic stop context, authority for a seizure ends when the tasks related to the stop are, or reasonably should have been, completed. Illinois v. Caballes, 543 U.S. 405, 407 (2005). Tasks related to a traffic stop include addressing the traffic violation that precipitated the stop; determining whether to issue a traffic ticket; and making inquiries incident to the traffic stop, such as checking the driver’s license, inspecting the vehicle’s proof of insurance and registration, and conducting a criminal record check of the driver. Rodriguez v. United States, 575 U.S. 348, 354-55 (2015); State v. Hale, 168 Idaho 863, 867, 489 P.3d 450, 454 (2021). Officers may not deviate from the purpose of a traffic stop by investigating (or taking safety precautions incident to investigating) other crimes without reasonable suspicion. See Rodriguez, 575 U.S. at 356. In this case, the magistrate court denied Dozal’s motion to suppress after concluding that any delay in the traffic stop was caused by Dozal’s “inability to provide legally required

3 documents.” The magistrate court also found credible the officer’s testimony that he “did not delay the business of the traffic stop to obtain the presence of” the drug dog. On intermediate appeal, the district court affirmed the denial of Dozal’s motion, concluding the magistrate court’s findings of fact and conclusions of law were supported by substantial and competent evidence.

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Related

Delaware v. Prouse
440 U.S. 648 (Supreme Court, 1979)
United States v. Cortez
449 U.S. 411 (Supreme Court, 1981)
Illinois v. Caballes
543 U.S. 405 (Supreme Court, 2005)
State v. Korn
224 P.3d 480 (Idaho Supreme Court, 2009)
State v. Atkinson
916 P.2d 1284 (Idaho Court of Appeals, 1996)
State v. Flowers
953 P.2d 645 (Idaho Court of Appeals, 1998)
State v. Rhonda Trusdall
318 P.3d 955 (Idaho Court of Appeals, 2014)
Rodriguez v. United States
575 U.S. 348 (Supreme Court, 2015)
State v. Pylican
477 P.3d 180 (Idaho Supreme Court, 2020)
State v. Hale
489 P.3d 450 (Idaho Supreme Court, 2021)
State v. Karst
509 P.3d 1148 (Idaho Supreme Court, 2022)

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Bluebook (online)
State v. Dozal, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-dozal-idahoctapp-2026.