State v. Nuss

CourtIdaho Court of Appeals
DecidedJanuary 12, 2026
Docket51366
StatusUnpublished

This text of State v. Nuss (State v. Nuss) 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. Nuss, (Idaho Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 51366

STATE OF IDAHO, ) ) Filed: January 12, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED MATTHEW STEVEN NUSS, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the First Judicial District, State of Idaho, Bonner County. Hon. Lamont C. Berecz, District Judge.

Judgment of conviction for possession of a controlled substance, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Kimberly A. Coster, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Kenneth K. Jorgensen, Deputy Attorney General, Boise, for respondent. ________________________________________________

LORELLO, Judge Matthew Steven Nuss appeals from his judgment of conviction for possession of a controlled substance. We affirm. I. FACTUAL AND PROCEDURAL BACKGROUND An officer initiated a traffic stop based on Nuss’s vehicle having an excessively loud muffler. While the officer conducted the traffic stop, he observed Nuss exhibiting behaviors indicative of a person under the influence. Among other behaviors, the officer observed Nuss profusely sweating, having rapid and shallow breathing, acting restless, talking rapidly, having darting eye movement, and moving around the vehicle. Based on these behaviors, the officer shifted his traffic stop inquiry to a driving under the influence (DUI) investigation. The officer

1 then called for backup in anticipation of conducting field sobriety tests. The officer asked Nuss to exit the vehicle, and when he did, he walked in an unnatural manner by side-stepping and moving backward while facing the officer. This behavior led the officer to believe Nuss was concealing something between his legs. The officer engaged Nuss in conversation while awaiting backup. During this period, the officer walked behind Nuss and observed an object wrapped in toilet paper. The object was later determined to contain over 100 fentanyl pills. Following the discovery of the pills, the officer abandoned the DUI investigation to focus on the possession of drugs investigation. The State charged Nuss with felony possession of a controlled substance, felony destruction or concealment of evidence, misdemeanor possession of drug paraphernalia, and a persistent violator enhancement. Nuss filed a motion to suppress the contraband that was found, arguing that the officer lacked reasonable suspicion to extend the traffic stop. Following a hearing, the district court denied the motion. Thereafter, Nuss entered a conditional guilty plea to possession of a controlled substance (I.C. § 37-2732(c)(1)), at which time he reserved his right to appeal the denial of his motion to suppress. In exchange for his guilty plea, the State dismissed the remaining charges. Nuss 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). III. ANALYSIS Nuss asserts the district court erred in denying his motion to suppress. Specifically, Nuss argues the officer did not have reasonable suspicion to extend the traffic stop. The State responds

2 that the record and applicable law support the district court’s denial of Nuss’s motion to suppress. We hold that Nuss has failed to show the district court erred in denying 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. The reasonableness of the suspicion must be evaluated upon the totality of the circumstances at the time of the stop. State v. Ferreira, 133 Idaho 474, 483, 988 P.2d 700, 709 (Ct. App. 1999). The reasonable suspicion standard requires less than probable cause but more than mere speculation or instinct on the part of the officer. Id. An officer may draw reasonable inferences from the facts in his or her possession, and those inferences may be drawn from the officer’s experience and law enforcement training. State v. Montague, 114 Idaho 319, 321, 756 P.2d 1083, 1085 (Ct. App. 1988). However, the justification for a motorist’s detention is not permanently fixed at the moment the traffic stop is initiated. State v. Wigginton, 142 Idaho 180, 183, 125 P.3d 536, 539 (Ct. App. 2005). An officer’s observations, general inquiries, and events succeeding the stop may--and often do--give rise to legitimate reasons for particularized lines of inquiry and further investigation by an officer. State v. Myers, 118 Idaho 608, 613, 798 P.2d 453, 458 (Ct. App. 1990). Furthermore, even without reasonable suspicion, officers may engage in lines of investigation unrelated to an

3 otherwise lawful traffic stop as long as doing so does not prolong the stop. See Caballes, 543 U.S.

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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. Montague
756 P.2d 1083 (Idaho Court of Appeals, 1988)
State v. Schevers
979 P.2d 659 (Idaho Court of Appeals, 1999)
State v. Ferreira
988 P.2d 700 (Idaho Court of Appeals, 1999)
State v. Valdez-Molina
897 P.2d 993 (Idaho Supreme Court, 1995)
State v. Atkinson
916 P.2d 1284 (Idaho Court of Appeals, 1996)
State v. Myers
798 P.2d 453 (Idaho Court of Appeals, 1990)
State v. Flowers
953 P.2d 645 (Idaho Court of Appeals, 1998)
State v. Wigginton
125 P.3d 536 (Idaho Court of Appeals, 2005)
Rodriguez v. United States
575 U.S. 348 (Supreme Court, 2015)
State v. Hale
489 P.3d 450 (Idaho Supreme Court, 2021)
State v. Couch
504 P.3d 388 (Idaho Court of Appeals, 2021)

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