COEUR d’ALENE — The Idaho Supreme Court has vacated a Post Falls man’s conviction for possessing child sexual abuse material because police obtained key evidence against him by unconstitutionally impounding his car.

A jury convicted Chadlen D. Smith, 40, of sexual exploitation of a child by possession of sexually exploitative material, a felony, in 2022. He received a 10-year prison sentence, the maximum possible under the law, with parole eligibility after five years. 

In a unanimous opinion penned by Justice Cynthia Meyer, the Supreme Court determined that the evidence obtained as a result of impounding Smith’s car should have been excluded from the trial. 

“Without this improperly obtained evidence, the state’s case against Smith for sexual exploitation of a child collapses,” Meyer wrote. 

The charges stemmed from 2021, when Smith was arrested for allegedly stalking a Post Falls Police Department employee. Electronics in Smith’s possession at the time of his arrest were seized as possible evidence in the stalking case. 

Forensic examination of the devices yielded images of nude children, toddlers and infants, as well as other photos of children that did not qualify as pornography, according to court records. Investigators also found evidence that Smith’s phone had visited a Russian website known for hosting child sexual abuse material. 

Police arranged to meet with Smith at Post Falls City Hall, purportedly to return his phone after the examination was complete, where they arrested him again, this time on charges of sexual exploitation of a child. 

After Smith’s arrest, authorities impounded his car, which he had parked at City Hall, and obtained a warrant to search the contents of a laptop, two thumb drives and a hard drive found inside the vehicle. 

The laptop contained thousands of “images and videos of child erotica,” according to the Supreme Court’s decision, including a specific photo collage of a nude child that formed “the sole basis for Smith’s sexual exploitation of a child charge.” 

Police cited department policy as the reason for impounding the car Smith had parked in the lot at City Hall. Attorneys for Smith argued that the impoundment violated his Fourth Amendment protections against unreasonable search and seizure and that any evidence obtained as a result of the impoundment should be suppressed. 

The Supreme Court found that the state did not show that the decision to impound Smith’s vehicle “served a community caretaking purpose,” making the impoundment unreasonable and unconstitutional. 

“Critically, the inventory search — and the resulting discovery of the laptop — stemmed directly from the unconstitutional impoundment of Smith’s vehicle,” Meyer wrote. “Without the unlawful impoundment, the evidence would not have been obtained.” 

The court vacated Smith’s conviction.