Justia Idaho Supreme Court Opinion Summaries

In 2021, Aaron Von Ehlinger, a first-year member of the Idaho State House of Representatives, was accused of rape by J.V., a legislative intern. They had dinner together and later went to Von Ehlinger’s apartment, where J.V. alleged that he sexually assaulted her. Von Ehlinger claimed the encounter was consensual. J.V. reported the incident, and a forensic nurse, Ann Wardle, conducted a sexual assault examination, documenting J.V.'s account and collecting evidence. Von Ehlinger was charged with rape and sexual penetration by use of a foreign object.The case proceeded to trial in April 2022 in the District Court of the Fourth Judicial District of Idaho. During the trial, Wardle testified about J.V.'s statements, which were admitted despite objections from Von Ehlinger’s defense on hearsay grounds. J.V. testified briefly but left the courtroom before cross-examination, leading the court to strike her testimony. The jury found Von Ehlinger guilty of rape but acquitted him of the second charge. The district court denied Von Ehlinger’s motion for acquittal or a new trial and sentenced him to 20 years in prison, with 8 years fixed.The Idaho Supreme Court reviewed the case. Von Ehlinger argued that his Sixth Amendment rights were violated by the admission of Wardle’s testimony and that the district court erred in allowing a leading question. The court found that Von Ehlinger failed to demonstrate that the admission of Wardle’s testimony was fundamental error, as his counsel’s failure to object could have been a tactical decision. The court also determined that any error in allowing the leading question was harmless, as Wardle did not answer the question directly. The court affirmed the judgment of conviction, concluding that there was sufficient evidence to support the jury’s verdict. View "State v. Von Ehlinger" on Justia Law

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court's denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith's motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and inventory search of his vehicle were reasonable and conducted according to police procedures. Smith was subsequently convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the State did not meet its burden to show that the police officer's decision to impound Smith's vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. As a result, the evidence obtained from the search was inadmissible, leading to the vacating of Smith's conviction. View "State v. Smith" on Justia Law

Daniel Ruiz Ortiz was convicted of second-degree murder and violating a no contact order (NCO). Ortiz appealed, arguing that the district court erred in denying his motion to suppress evidence obtained during a warrantless search of his home and a subsequent search conducted with a warrant. The district court relied on the Idaho Supreme Court's decision in State v. Rebo, which held that Ortiz lacked Fourth Amendment standing to challenge the warrantless search because the NCO prohibited him from being within 300 feet of the residence.The district court found that Ortiz did not have standing to challenge the search, as he was prohibited by the NCO from being near the home. Ortiz's case proceeded to a jury trial, where he was found guilty of second-degree murder and violating the NCO. He was sentenced to life in prison, with the first thirty years fixed. Ortiz appealed the denial of his motion to suppress, arguing that the Rebo decision should be overruled or that his case was distinguishable from Rebo.The Idaho Supreme Court reviewed the case and declined to overrule Rebo, finding that Ortiz failed to demonstrate that the decision was manifestly wrong. The court also found that while Ortiz's case was factually distinguishable from Rebo, he still lacked Fourth Amendment standing to challenge the warrantless search. The court held that Ortiz did not have a reasonable expectation of privacy in the home due to the NCO and that law enforcement's entry into the home was justified by exigent circumstances, as they were concerned for Ruiz's safety.The Idaho Supreme Court affirmed the district court's decision, concluding that Ortiz did not have standing to challenge the warrantless search of his home. View "State v. Ortiz" on Justia Law

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law

A mother and her fiancé filed a petition to terminate the biological father's parental rights and allow the fiancé to adopt the child. The mother did not serve the father with the petition, and he did not participate in the proceedings. The magistrate court terminated the father's parental rights and granted the adoption. The father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. The magistrate court denied the second motion, citing res judicata. The district court reversed this decision, finding that the father's due process argument warranted consideration.The Idaho Supreme Court reviewed the case. The court held that the father's Rule 60(b)(4) motion, which alleged a fundamental error violating his constitutional right to due process, was not barred by res judicata. The court applied the fundamental error doctrine, which allows for exceptions to procedural bars when a fundamental constitutional right is at stake. The court also rejected the mother's arguments that the father's motion was barred by the doctrines of claim splitting, invited error, appellate waiver, and the law of the case.The Idaho Supreme Court affirmed the district court's decision to remand the case to the magistrate court for an evidentiary hearing to determine whether the father's Rule 60(b)(4) motion was timely and whether the termination and adoption judgment was void. The court also awarded the father partial attorney fees on appeal for defending against certain arguments made by the mother. View "Doe v. Doe" on Justia Law

Gerardo Raul Chavez was convicted of second-degree murder for the 2016 killing of Vason Widaman. While in custody for a probation violation, Chavez made incriminating statements to a cellmate, Manuel Acevedo, who was acting as a confidential informant. The State sought to introduce these recordings at trial. Chavez moved to suppress the statements, but the district court only partially granted the motion, suppressing a few statements. The jury acquitted Chavez of first-degree murder but convicted him of second-degree murder with a firearm enhancement. Chavez was sentenced to an indeterminate life sentence with a 42-year fixed term. Post-trial, Chavez's motions for a new trial and permission to contact jurors were denied.Chavez appealed, arguing that the district court erred in denying his motion to suppress, abused its discretion in sentencing, violated his constitutional rights by considering acquitted conduct at sentencing, and erred in denying his motion to contact jurors. The Idaho Supreme Court reviewed the case.The Idaho Supreme Court affirmed the district court's decision. It held that the district court did not err in admitting Chavez's statements, as they were not deliberately elicited by Acevedo. The court also found no abuse of discretion in the 42-year fixed sentence, noting that it fell within statutory limits and was justified by the aggravating factors. The court further held that considering acquitted conduct at sentencing did not violate Chavez's constitutional rights. Finally, the court found no abuse of discretion in denying the motion to contact jurors, as Chavez failed to show good cause for suspecting juror misconduct. View "State v. Chavez" on Justia Law

Michael Anthony Pulizzi was convicted of felony possession of methamphetamine and destruction, alteration, or concealment of evidence. Pulizzi argued that the district court erred in denying his motion to suppress evidence obtained from warrantless searches and seizures of his trash, which he claimed violated his rights under the Idaho Constitution. He contended that the Twin Falls City waste collection ordinances created an objectively reasonable expectation of privacy in his trash.The District Court of the Fifth Judicial District of Idaho denied Pulizzi’s motion to suppress, finding that the waste collection ordinance did not create a reasonable expectation of privacy. The court concluded that the ordinance did not mandate participation in the city’s waste collection program and that the prohibition against collecting garbage for monetary gain did not apply to law enforcement officers. Pulizzi then pled guilty to the charges under a conditional plea agreement, preserving his right to appeal the suppression ruling.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court’s judgment. The court held that the waste collection ordinance did not create an objectively reasonable expectation of privacy in Pulizzi’s trash. The court declined to reconsider its previous holdings in State v. Donato and State v. McCall, which aligned with the U.S. Supreme Court’s decision in California v. Greenwood, stating that there is no reasonable expectation of privacy in garbage left for collection in a public area. The court found that the ordinance’s purpose was to promote public health and safety, not to protect privacy interests in curbside garbage. Consequently, the court affirmed Pulizzi’s conviction. View "State v. Pulizzi" on Justia Law

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt earlier this year due to the inability to establish reliable peripheral intravenous access. The execution team spent nearly an hour attempting to establish venous access in various parts of Creech’s body, but each attempt resulted in vein collapse, leading to the procedure being halted. Following this, Creech sought post-conviction relief, which was denied by the district court and affirmed on appeal.While his post-conviction appeal was pending, Creech applied for a writ of habeas corpus in the district court, arguing that any further attempt to carry out his death sentence would violate his constitutional rights. The district court summarily dismissed Creech’s application with prejudice. Creech appealed, contending that the State’s revised standard operating procedure and execution protocols constitute cruel and unusual punishment.The Supreme Court of the State of Idaho reviewed the case. The court noted that the Idaho Department of Correction had modified its standard operating procedure for executions to allow a qualified physician to establish a central line if peripheral vein access is not attainable. Creech’s application for a writ of habeas corpus included three claims, but only Claim Two, which challenged the use of a central venous line as cruel and unusual punishment, was before the court on appeal.The court held that Creech failed to establish a prima facie challenge to the State’s method of execution. The court found that the use of a central line catheter is a common medical procedure and does not rise to the level of indecency or cruelty prohibited by the United States Constitution. Additionally, Creech failed to propose an alternative method of execution, as required to assert a “method of execution” challenge. The Supreme Court of the State of Idaho affirmed the district court’s order of dismissal. View "Creech v. Randy Valley" on Justia Law

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt in early 2024 due to the inability to establish reliable intravenous access. Following this, Creech filed a petition for post-conviction relief, arguing that any further attempt to execute him would violate his constitutional rights under the Fifth Amendment’s Double Jeopardy Clause and the Eighth Amendment’s prohibition against cruel and unusual punishment.The District Court of the Fourth Judicial District of Idaho dismissed Creech’s petition, construing his Eighth Amendment argument as a challenge to the method of execution, which it determined could not be litigated in a post-conviction action. The court suggested that Creech could pursue his Eighth Amendment challenge through other legal avenues, such as a 42 U.S.C. § 1983 action. The court also addressed the merits, finding that a second execution attempt did not violate the Fifth Amendment as it did not impose more punishment than authorized, nor did it violate the Eighth Amendment as the failed attempt did not involve intentional or malicious infliction of unnecessary pain.The Supreme Court of Idaho affirmed the district court’s dismissal. It held that Creech’s claims were properly raised under Idaho Code section 19-2719 but found no genuine issue of material fact warranting an evidentiary hearing. The court determined that the failed execution did not constitute cruel and unusual punishment under the Eighth Amendment, as the psychological strain and pain experienced were inherent in any execution method. Additionally, the court ruled that a second execution attempt did not violate the Double Jeopardy Clause, as the initial attempt did not complete the punishment authorized by the legislature. Creech’s state constitutional claims were not considered as they were not adequately preserved for appeal. View "Creech v. State" on Justia Law

In this case, the State of Idaho removed five minor children from their parents' home following allegations of physical abuse. The children ranged in age from sixteen years to fourteen months. Law enforcement responded to a report of an altercation between the mother and the eldest child, during which the mother admitted to hitting the child with a plastic hanger. Other children reported frequent physical discipline, including being hit with belts and hands. The children were declared to be in imminent danger and were removed from the home.The Bannock County Prosecutor’s Office filed a petition under the Child Protective Act (CPA) to place the children in the custody of the Idaho Department of Health and Welfare (IDHW). The magistrate court held a shelter care hearing and found reasonable cause to believe the children were in danger, placing them in temporary custody of IDHW. The parents objected, arguing that the removal violated their constitutional rights and that the magistrate court’s findings were unsupported by substantial evidence.The Idaho Supreme Court reviewed the case and affirmed the magistrate court’s adjudicatory decree. The Court declined to rule on the constitutionality of the initial removal because the parents failed to raise the issue in the lower court. The Court also found that the challenge to the shelter care order was moot because it was supplanted by the adjudicatory decree. The Court held that the magistrate court did not abuse its discretion by allowing the older children to remain in the courtroom during the hearing and found that substantial and competent evidence supported the magistrate court’s decision to vest legal custody of the children in IDHW. The Court also declined to consider the parents' argument under the Idaho Parental Rights Act because it was raised for the first time on appeal. View "IDHW v. Doe" on Justia Law