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Idaho Supreme Court Upholds Drug Conviction Despite Fourth Amendment Challenge

The Idaho Supreme Court affirmed the drug conviction of Kaylee Horn, who challenged the legality of a search conducted during a probation check of her housemate. The court rejected Horn's motion to suppress methamphetamine and drug paraphernalia evidence found during the search.

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2 min readcourtlistener
Seal of the Idaho Supreme Court

Case Information

Case No.:
50788

Key Takeaways

  • Idaho Supreme Court affirmed Horn's drug conviction and rejected her Fourth Amendment suppression motion
  • Horn argued officers violated her rights by searching despite her refusal to consent during probation check
  • Case involved novel application of Georgia v. Randolph precedent to probation supervision contexts
  • Both Horn and her probationer housemate Richard Noyes were convicted in joint jury trial

The Idaho Supreme Court affirmed the drug conviction of Kaylee Horn, rejecting her Fourth Amendment challenge to evidence seized during a probation verification search at her home. The court issued its opinion December 9, 2024, in *State v. Horn*, upholding Horn's convictions for possession of methamphetamine, drug paraphernalia possession, and being a persistent violator.

The case arose from a residence verification and probation search conducted by law enforcement officers in connection with Horn's housemate, Richard Noyes, who was on probation. During the search, officers discovered drug evidence that led to charges against both Horn and Noyes. Horn moved to suppress the evidence, arguing that the officers' entry into her home violated her Fourth Amendment rights because she was present when officers arrived and explicitly refused to give consent to the search.

The district court denied Horn's motion to suppress, and the case proceeded to a joint jury trial with Noyes. Both defendants were found guilty by the jury. Horn subsequently appealed the district court's judgment of conviction, raising constitutional challenges to the search.

The Idaho Supreme Court's decision addressed the intersection of probation supervision requirements and Fourth Amendment protections in shared living situations, ultimately determining that the search was legally justified under established precedents governing probationer searches.

Topics

drug possessionFourth Amendmentsearch and seizureconsentprobation searchSixth Amendmentconfrontation clausesuppression of evidence

Original Source: courtlistener

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