State v. Fletcher

The Supreme Court of Idaho held that drug dog sniffs of a vehicle’s exterior did not constitute searches under Article 1, Section 17 of the Idaho Constitution because they only revealed the presence of contraband, which did not implicate a legitimate privacy interest. The court also held that the Idaho Constitution did not provide greater protections than the Fourth Amendment for the automobile exception to the search warrant requirement. Here, the evidence was sufficient to support the finding that officers had probable cause for a warrantless search of the defendant’s vehicle based on the drug dog alert.