STATE v. BELL

Docket No. 49099.

533 P.3d 1247 (2023)

STATE of Idaho, Plaintiff-Appellant, v. Jonathan Elston BELL, Defendant-Respondent.

Supreme Court of Idaho, Boise, February 2023 Term.

Opinion Filed: August 15, 2023.


Attorney(s) appearing for the Case

Raúl R. Labrador , Idaho Attorney General, Boise, attorney for Appellant. Kacey L. Jones argued.

Eric D. Fredericksen , State Appellate Public Defender, Boise, attorney for Respondent. Jenny Swinford argued.


This appeal presents another examination of the scope of our holding in State v. Clarke, 165 Idaho 393, 446 P.3d 451 (2019). There, we held that an individual may not be arrested without a warrant for a misdemeanor that was completed outside the arresting officer's presence. The State of Idaho brings this appeal...

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