by Logan Finney, Idaho Reports

The Idaho Supreme Court has vacated a man’s sexual exploitation conviction because Post Falls police obtained key evidence in the case by unconstitutionally impounding his car, a violation of the Fourth Amendment right against unreasonable searches and seizures.

A Kootenai County jury in 2022 convicted Chadlen Dewayne Smith of sexual exploitation of a child by possession of sexually exploitative material. As reported by the Coeur d’Alene Press, First District Judge Barbara Duggan sentenced him to the maximum sentence of 10 years in prison with eligibility for parole in 2027.

In the lead-up to those charges, Smith interacted with officers several times after stalking allegations against him, ultimately resulting in his arrest. During the arrest, the officer seized two cell phones and a digital camera. Police cited Smith with misdemeanor stalking in the second degree, a charge the court later dismissed.

Officers also obtained a warrant to search his phone for pictures in support of the stalking charge. During the search, police found graphic photos of infants. An expanded warrant uncovered visits to a Russian child pornography website.

Officers contacted Smith to inform him the forensic examination of his phone was complete and coordinated with him to return the phone at Post Falls City Hall, where they arrested him a second time. After his arrest, law enforcement impounded his car, which he had parked at City Hall, and found more electronic devices. Another warrant in support of the child sexual exploitation charge allowed officers to search the devices, uncovering thousands more images.

Smith’s car was impounded under department policy, despite being parked appropriately in the lot at City Hall where he met police under the pretext of officers returning his phone. His attorneys argued that because he had legally parked, that impoundment was illegal. The court agreed in a unanimous opinion, penned by Justice Cynthia Meyer.

The Fourth Amendment of the U.S. Constitution protects citizens from unreasonable search and seizure without a warrant. Based on that principle, the “exclusionary rule” forbids the government from presenting evidence in court that was illegally obtained.

“Because Smith’s arrest was supported by probable cause, the seizure of his phone was lawful,” the court ruled, as was the inventory search of the car. “Critically, however, the origin of the vehicle’s inventory search—the impoundment itself—is a seizure, which is also subject to the Fourth Amendment prohibition against unreasonable seizures.”

“The State’s argument that the impoundment was carried out according to standard Post Falls Police Department procedures following Smith’s arrest is misplaced,” Meyer wrote. “Before police officers may conduct an inventory search, the warrantless impoundment must nevertheless be reasonable under the Fourth Amendment.”

The court ruled the police did not show sufficient justification to impound Smith’s car after the second arrest. Police must meet a “community caretaking” purpose to impound a car.

“The record lacks any indication that the impound served a legitimate community caretaking purpose, such as being parked in a no-parking zone, obstructing traffic, or violating any parking ordinances,” the opinion states.

The court vacated Smith’s conviction and overturned the lower court’s decision not to exclude the evidence from court.

“Because the impoundment and subsequent inventory search violated the Fourth Amendment, all evidence derived from the search must be excluded under the exclusionary rule. This includes the laptop and digital storage devices found in Smith’s vehicle, as well as any evidence obtained through subsequent search warrants,” the court ruled. “Without this improperly obtained evidence, the State’s case against Smith for sexual exploitation of a child collapses.”

The online case record reflects the Supreme Court’s opinion, but there are not any additional hearings yet scheduled as of Monday afternoon.

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