State v. Prishmont

CourtIdaho Court of Appeals
DecidedMarch 25, 2026
Docket51441
StatusUnpublished

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

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket Nos. 51441 & 51442

STATE OF IDAHO, ) ) Filed: March 25, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED JEREMY JAMES PRISHMONT, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the First Judicial District, State of Idaho, Kootenai County. Hon. Barry McHugh, District Judge.

Judgments of conviction for two counts of possession of a controlled substance, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Kiley A. Heffner, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Michael MacEgan, Deputy Attorney General, Boise, for respondent. ________________________________________________

LORELLO, Judge In these consolidated cases, Jeremy James Prishmont appeals from his judgments of conviction for two counts of possession of a controlled substance. We affirm. I. FACTUAL AND PROCEDURAL BACKGROUND In Docket No. 51441, an officer responded to a store after receiving a report that a woman had stolen merchandise and put it in her purse or coat and then drove away in a red truck with a ski rack on top. The officer saw a vehicle matching that description leaving the store parking lot and initiated a traffic stop. Prishmont was in the passenger seat. The driver said she had been in the store to purchase cigarettes but left because her card was declined. The driver then consented to a search of her purse. The officer found a green, leafy substance that she recognized to be

1 marijuana. Based on this discovery, the officer searched the vehicle and found drugs, drug paraphernalia, and merchandise from the store. Prishmont was transported to jail, where officers searched him and discovered a wrapped-up piece of foil with brown residue in his back pocket. Prishmont was subsequently charged with two counts of possession of a controlled substance (I.C. § 37-2732(c)(1)) and felony introducing major contraband into a correctional facility (I.C. § 18-2510(3)). Prishmont was released on bond pending further proceedings. In Docket No. 51442, an officer stopped Prishmont as he left a parking lot for failing to use a turn signal and failing to come to a complete stop before entering a roadway. During the traffic stop, the officer smelled burnt marijuana coming from Prishmont’s vehicle. As a result, the officer conducted a search of the vehicle and discovered several pieces of tin foil with burnt residue that appeared to be fentanyl, a burnt pill that the officer also recognized as fentanyl, and methamphetamine inside a small container on a necklace Prishmont was wearing. Prishmont was charged with two counts of possession of a controlled substance (I.C. § 37-2732(c)(1)) and being a persistent violator (I.C. § 19-2514). In Docket No. 51441, Prishmont moved to suppress all evidence and statements obtained because of the warrantless search of the vehicle, arguing the search of the driver’s purse did not justify the subsequent search of the vehicle. In Docket No. 51442, Prishmont moved to suppress all evidence obtained from the warrantless search of his vehicle, arguing the officer did not have probable cause to search the vehicle because the officer could not have reasonably believed he smelled marijuana emanating from the vehicle. The district court denied both of Prishmont’s motions to suppress. Pursuant to a plea agreement, Prishmont pled guilty to one count of possession of a controlled substance in Docket No. 51441, and one count of possession of a controlled substance in Docket No. 51442. In exchange for his guilty pleas, the other charges were dismissed. Prishmont 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

2 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 Prishmont challenges the denial of his motions to suppress in both cases. The motions to suppress stem from two separate warrantless searches--one of vehicle in which Prishmont was a passenger and one of his vehicle. The State responds that the district court correctly concluded both searches were constitutionally permissible. We hold that both the search of Prishmont’s vehicle and the search of the vehicle in which he was a passenger were constitutionally permissible. A warrantless search is presumptively unreasonable unless it falls within certain special and well-delineated exceptions to the warrant requirement. Coolidge v. New Hampshire, 403 U.S. 443, 454-55 (1971); State v. Ferreira, 133 Idaho 474, 479, 988 P.2d 700, 705 (Ct. App. 1999). The automobile exception to the warrant requirement allows police to search a vehicle without a warrant when there is probable cause to believe the vehicle contains contraband or evidence of a crime. State v. Anderson, 154 Idaho 703, 706, 302 P.3d 328, 331 (2012). Probable cause is the possession of information that would lead a person of ordinary care and prudence to believe or entertain an honest and strong presumption that a person they have placed under arrest is guilty of a crime. State v. Williams, 162 Idaho 56, 66, 394 P.3d 99, 109 (Ct. App. 2016). Probable cause is not measured by the same level of proof required for conviction. Id. Rather, probable cause deals with the factual and practical considerations on which reasonable and prudent persons act. Brinegar v. United States, 338 U.S. 160, 175 (1949); Williams, 162 Idaho at 66, 394 P.3d at 109. When reviewing an officer’s actions, the court must judge the facts against an objective standard. Williams, 162 Idaho at 66, 394 P.3d at 109. That is, would the facts available to the officer, at the moment of the seizure or search, warrant a reasonable person in holding the belief that the action taken was appropriate. Id. A. Docket No. 51441--Motion to Suppress “Mindful” that substantial and competent evidence supports the district court’s findings and “mindful” of case law, Prishmont argues that law enforcement lacked probable cause to

3 conduct a warrantless search of the vehicle in which he was a passenger. More specifically, Prishmont asserts that finding marijuana in a purse that the driver handed from the vehicle to the officer through the window was insufficient to support a warrantless search of the vehicle. The State responds that, pursuant to the automobile exception, the presence of the marijuana in the purse removed from the vehicle provided sufficient probable cause for officers to search the vehicle for other contraband.

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Related

Brinegar v. United States
338 U.S. 160 (Supreme Court, 1949)
Coolidge v. New Hampshire
403 U.S. 443 (Supreme Court, 1971)
State v. Steven Clay Anderson
302 P.3d 328 (Idaho Supreme Court, 2012)
State v. Johnson
266 P.3d 1161 (Idaho Court of Appeals, 2011)
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. Flowers
953 P.2d 645 (Idaho Court of Appeals, 1998)
State v. Chad Lee Williams
394 P.3d 99 (Idaho Court of Appeals, 2016)
State v. Gonzales
789 P.2d 206 (Idaho Court of Appeals, 1990)

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