State v. Nelson

CourtIdaho Court of Appeals
DecidedJanuary 14, 2025
Docket50600
StatusUnpublished

This text of State v. Nelson (State v. Nelson) 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. Nelson, (Idaho Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 50600

STATE OF IDAHO, ) ) Filed: January 14, 2025 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED EDWIN E. NELSON, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the Seventh Judicial District, State of Idaho, Teton County. Hon. Steven W. Boyce, District Judge.

Judgment of conviction for felony driving under the influence and resisting or obstructing an officer, affirmed.

Murray, Ziel & Johnston, PLLC; Paul D. Ziel, Idaho Falls, for appellant.

Hon. Raúl R. Labrador, Attorney General; John C. McKinney, Deputy Attorney General, Boise, for respondent. ________________________________________________

GRATTON, Chief Judge Edwin E. Nelson appeals from his judgment of conviction for felony driving under the influence and resisting or obstructing an officer. We affirm. I. FACTUAL AND PROCEDURAL HISTORY In February 2019, Deputy Sewell discovered Nelson’s vehicle stuck in a snowbank with the engine running. Nelson exhibited signs of intoxication, including slurred speech, glassy eyes, impaired memory, and difficulty maintaining balance. Nelson refused to participate in field sobriety or breath tests. After obtaining a warrant, deputies forcibly took a blood sample, which confirmed Nelson’s intoxication. Nelson was arrested and charged with felony DUI, Idaho Code § 18-8004; resisting/obstructing officers, I.C. § 18-705; and possession of an open container, I.C. § 23-505(2).

1 Nelson challenged the evidence against him, filing multiple motions to suppress and motions in limine. Nelson argued that Deputy Sewell “had no reasonable suspicion to conduct an investigatory stop of [him].” Following a hearing, the district court denied Nelson’s suppression motion. The district court concluded: (1) Deputy Sewell’s initial contact with Nelson was consensual; (2) Deputy Sewell’s contact with Nelson did not violate the “community caretaking” function; and (3) soon after contacting Nelson, Deputy Sewell developed reasonable suspicion to detain Nelson to investigate whether he was in physical control of his vehicle while under the influence of alcohol. Nelson also claimed that his blood was taken unconstitutionally and that the chain of custody of the blood draw evidence was compromised. Nelson attempted to exclude the blood alcohol content (BAC) test results by presenting expert testimony questioning the reliability of the testing procedures and handling of the blood samples. The district court denied Nelson’s challenge and allowed the blood test evidence to be admitted. The district court also limited the testimony of Nelson’s expert as to the blood draw and handling issues. Nelson further contended that he was denied counsel and the opportunity to independently test the blood. The district court denied Nelson’s claims that his due process rights were violated by not being allowed to contact an attorney immediately after his arrest. The district court also rejected Nelson’s claims relative to the timeliness of the return of the search warrant. At trial, Nelson objected to one of the State’s rebuttal witnesses, claiming the State’s disclosure of the witness was not timely; the district court overruled the objection. Nelson was convicted of felony DUI and resisting or obstructing an officer. Nelson appeals. II. STANDARD OF REVIEW The standard of review of a suppression motion is bifurcated. When a decision on a motion to suppress is challenged, we accept the trial court’s findings of fact that are supported by substantial evidence, but we freely review the application of constitutional principles to the facts as found. State v. Atkinson, 128 Idaho 559, 561, 916 P.2d 1284, 1286 (Ct. App. 1996). At a suppression hearing, the power to assess the credibility of witnesses, resolve factual conflicts, weigh evidence, and draw factual inferences is vested in the trial court. State v. Valdez-Molina, 127 Idaho 102, 106, 897 P.2d 993, 997 (1995); State v. Schevers, 132 Idaho 786, 789, 979 P.2d 659, 662 (Ct. App. 1999).

2 Where a defendant claims that his or her right to due process was violated, we defer to the trial court’s findings of fact, if supported by substantial evidence. State v. Smith, 135 Idaho 712, 720, 23 P.3d 786, 794 (Ct. App. 2001). However, we freely review the application of constitutional principles to those facts found. Id. Over questions of law, we exercise free review. State v. O’Neill, 118 Idaho 244, 245, 796 P.2d 121, 122 (1990). When a trial court’s discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine whether the trial court: (1) correctly perceived the issue as one of discretion; (2) acted within the boundaries of such discretion; (3) acted consistently with any legal standards applicable to the specific choices before it; and (4) reached its decision by an exercise of reason. State v. Herrera, 164 Idaho 261, 270, 429 P.3d 149, 158 (2018). III. ANALYSIS Nelson raises several issues on appeal: (1) whether Deputy Sewell had reasonable, articulable suspicion to investigate Nelson, and whether his actions fell within the scope of the community caretaking function; (2) whether Nelson’s Fifth Amendment rights were violated due to denial of access to legal counsel at the time of his arrest, and whether he had a meaningful opportunity to independently test his blood; (3) whether his due process rights were infringed by the late return of the search warrant; (4) whether the district court erred by limiting Nelson’s expert witness testimony; and (5) whether the district court abused its discretion by allowing a late disclosed rebuttal witness to testify. A. Initial Encounter Nelson argues that Deputy Sewell lacked reasonable articulable suspicion to conduct an investigatory stop. Nelson also contends the district court erred in finding that Deputy Sewell’s contact with Nelson was justified as a community caretaking function because his subjective belief that Nelson’s vehicle may have been stuck in the snow was not reasonable in view of all the surrounding circumstances. The State contends that the initial encounter was consensual. The Fourth Amendment to the United States Constitution prohibits unreasonable seizures. U.S. CONST. amend. IV. When a defendant seeks to suppress evidence allegedly obtained as a result of an illegal seizure, the burden of proving that a seizure occurred is on the defendant. State v. Page, 140 Idaho 841, 843, 103 P.3d 454, 456 (2004). The test to determine if an individual is seized for Fourth Amendment purposes is an objective one. State v. Willoughby, 147 Idaho 482,

3 486, 211 P.3d 91, 95 (2009). A seizure occurs only if, in view of all of the circumstances surrounding the incident, a reasonable person would have believed that he was not free to leave. State v. Baker, 141 Idaho 163, 165, 107 P.3d 1214, 1216 (2004). An encounter between a law enforcement officer and a citizen does not trigger Fourth Amendment scrutiny unless it is nonconsensual. Willoughby, 147 Idaho at 486, 211 P.3d at 95. A seizure under the meaning of the Fourth Amendment occurs only when the officer, by means of physical force or show of authority, has in some way restrained the liberty of a citizen. Id.

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Bluebook (online)
State v. Nelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-nelson-idahoctapp-2025.