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Comparative Constitutional Law Keyed to Sutton, 5th Ed.
State v. Koivu
Citation:
272 P.3d 483 (Idaho 2012)Facts
Randy Koivu was convicted of methamphetamine possession in Boundary County in 2004 and sentenced to probation with conditions including payment of fines and costs. After probation violations, he was incarcerated and released in July 2009. In December 2009, a Boundary County court clerk filed affidavits regarding unpaid fines, and the district court issued a warrant of attachment for Koivu’s arrest to show cause why he should not be held in contempt. On March 5, 2010, Bonner County deputies stopped Koivu for speeding and discovered the outstanding warrant. They arrested him and transported him to jail, where methamphetamine was found during the booking search. The Boundary County court later dismissed the warrant, finding it had been issued without jurisdiction because the fines were probation conditions that terminated when probation was revoked. Neither law enforcement nor prosecutors were involved in generating the warrant.
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