State v. Iams

Warrantless entries and searches of areas in which a defendant has a privacy interest are unreasonable unless they fall within one of the few exceptions to the warrant requirement

This case arose out of a routine traffic stop by an officer in Bend who noticed that the defendant’s tail light was out and that she had been driving erratically on the road. The officer turned on his lights to pull the defendant over and she turned into her driveway and stopped. Based on the defendant’s behavior, the officer asked her if she would consent to a field sobriety test and she agreed. The defendant filed a motion to suppress the evidence obtained during the field sobriety test, alleging that the officer needed a warrant to enter her driveway, making the search unconstitutional and that she did not voluntarily consent to perform the field sobriety test. The motion was denied and at trial she was convicted of a DUI. She appealed and again asserted that the evidence against her should be suppressed. 

The Oregon Court of Appeals held that the trial court erred in denying the defendant’s motion to suppress based on the lawfulness of the officer’s initial stop based on reasonable suspicion because the state failed to state how the officer’s right to stop the defendant’s car fell within one of the exceptions to the warrant requirement. Additionally, the court of appeals sent the issue of whether there was implied consent for the officer to be on the defendant’s property back to the trial court because they had not initially addressed the issue. Finally, the court upheld the trial court’s decision as to the defendant’s voluntariness of the field sobriety test, determining that the defendant’s consent was freely and voluntarily given. The Oregon Court of Appeals vacated and remanded the decision back to the trial court.