State v. Campbell

Summary

The Idaho Supreme Court affirmed the denial of Campbell’s suppression motion and his resulting conviction. It held that the trooper’s unsupported use of handcuffs converted the investigative detention into an unreasonable de facto arrest, but concluded that the evidence was nevertheless admissible under the inevitable-discovery exception because a lawful parallel investigative path would have led to the same search. The Court therefore did not reach Campbell’s argument that the federal attenuation doctrine provides insufficient protection under the Idaho Constitution.