Justia Idaho Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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Petitioner Sherri Ybarra, the Idaho Superintendent of Public Instruction, petitioned the Idaho Supreme Court for a declaratory judgment, writ of mandamus, or writ of prohibition to remedy various alleged constitutional violations by the Idaho Legislature and the Idaho State Board of Education related to the funding and supervision of eighteen employees currently working in the Idaho Department of Education. During the 2020 legislative session, the Idaho Legislature passed two appropriation bills - Senate Bills 1409 and 1410 - which transferred supervision of eighteen full-time job positions within the Department’s Technology Group to the Board along with approximately $2.7 million in funding for those positions. The Superintendent argues that “by splitting eighteen employees away from three other workers and eliminating all funding for the office space, rent, and the maintenance and upgrading of the Department’s computers, this line item appropriation decentralizes and damages operations.” She also claimed these bills were the Legislature’s attempt to “strip the Superintendent of her authority through the budget process,” in retaliation for her failure to support a 2019 revised school funding formula. To effectuate such relief, the Superintendent invoked the Supreme Court's original jurisdiction, seeking a declaratory judgment that the Appropriation Bills were unconstitutional. The Superintendent sought a writ of mandamus and/or prohibition that would allow SB 1409's funding appropriation to the Board remain intact, but would restore the Superintendent's full management authority over the Technology Group. The Supreme Court found the Appropriations Bills constitutional, thereby declining to address requests for writs of mandamus and/or prohibition. View "Ybarra v. Legislature of the State of Idaho" on Justia Law

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Quentin Nava appealed after he was convicted on one count of lewd and lascivious conduct and one count of sex abuse. The charges arose from an approximately two-day period in July 2016 when Nava was staying in the home of a female friend, her twelve-year-old daughter, her twelve-year-old niece, as well as other friends and relatives who were staying at the woman’s house. He argued that the district court erred when it denied his motion to sever the two counts. Nava argued the similarities between the two counts did not constitute a common scheme or plan as to justify joinder of the two charges. The Idaho Court of Appeals agreed, and vacated Nava’s judgment of conviction. The State petitioned for review, and finding no reversible error in the appellate court's judgment, the Idaho Supreme Court affirmed. View "Idaho v. Nava" on Justia Law

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Clinton Haggard appealed a district court’s decision to affirm a magistrate court’s judgment of conviction. After a trial, the magistrate court found Haggard guilty of misdemeanor domestic battery in violation of Idaho Code section 18-918(3)(b). The issue presented for the Idaho Supreme Court's review was whether aggard effectively waived his right to a jury trial. The Court found Haggard’s waiver was ineffective because the magistrate court did not, in open court, inquire into whether the waiver was knowing, intelligent, and voluntary. The Court therefore reversed the district court’s decision and remanded this case with instructions to the district court to remand this case to the magistrate court with instructions to vacate the judgment of conviction. View "Idaho v. Haggard" on Justia Law

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Over a period of several months, William Dix bought several thousand dollars’ worth of goods from Grainger Supply on credit. On the same days he bought the goods, he pawned them. Dix was charged with grand theft and burglary, and pleaded not guilty to both counts. At trial, the State argued that Dix committed theft by obtaining the goods on credit without intending to pay for them, and committed burglary by receiving loans from the pawn shop in exchange for the goods based on false representations that he owned them. After the close of the State’s case-in-chief, Dix moved for a judgment of acquittal under Idaho Criminal Rule 29 on both charges, arguing that under Idaho v. Bennett, 246 P.3d 387 (2010), he became the owner of the goods once he obtained possession of them from Grainger, and as the owner, he could lawfully pawn them. The district court denied Dix’s motion, and the jury subsequently returned guilty verdicts on both counts. After trial, Dix renewed his Rule 29 motion on the burglary charge, and this motion was also denied. The district court entered an order withholding judgment and placing Dix on probation for eight years. Dix timely appealed, and the Court of Appeals affirmed. Upon certiorari review, the Idaho Supreme Court reversed Dix’s convictions and remanded the case to the district court with instructions to enter a judgment of acquittal on both counts. View "Idaho v. Dix" on Justia Law

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John Rodriguez sold a firearm to an individual who had visible gang tattoos and had previously identified himself as a member of the Norteno gang, but who was actually an informant paid by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The State charged Rodriguez with two counts of providing firearms to criminal gang members under Idaho Code section 18-8505 and a sentencing enhancement for providing the firearm to further criminal gang purposes under Idaho Code section 18-8503(1)(b). After trial, the jury returned a verdict of guilty as to Count I but not guilty as to Count II and answered "no" to the sentencing enhancement question. The district court suspended a unified sentence of ten years and placed Rodriguez on probation for ten years. Rodriguez appealed, arguing his conviction should have been vacated because criminalizing the sale or transfer of firearms to gang members without the intent to further gang activity, Idaho Code section 18-8505 violated rights guaranteed by the federal Constitution: the freedom of association under the First Amendment, the right to bear arms under the Second Amendment, and the due process requirement of personal guilt under the Fourteenth Amendment. Finding that Rodriguez forfeited his constitutional challenges by failing to present them to the trial court, the Idaho Supreme Court affirmed. View "Idaho v. Rodriguez" on Justia Law

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Steven Chambers appealed his conviction entered upon his "Alford" plea to battery with intent to commit a serious felony. Chambers was initially charged with forcible rape against a young woman. Pursuant to I.R.E. 412, Chambers moved to introduce evidence of a purportedly false allegation "N.S." made against a different individual approximately six months after her alleged rape by Chambers. The State objected to the admission of such evidence. After a Rule 412 hearing, the district court excluded evidence of the purportedly false allegation. The Idaho Court of Appeals heard Chambers’ appeal and held that false allegations made after the charged conduct could be admissible. However, the appellate court concluded that Chambers had failed to prove falsity at the Rule 412 hearing. After its review, the Idaho Supreme Court concluded the district court erred when it determined that Rule 412 contained a temporal requirement that the false allegation must precede the events giving rise to the charge. Further, the district court abused its discretion by applying the wrong balancing test. The Supreme Court announced guidelines and procedure for the district court to use on remand to determine whether evidence of the purportedly false allegation was admissible. Judgment of conviction was vacated and the matter remanded for further proceedings. View "Idaho v. Chambers" on Justia Law

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Britain Lee Barr pleaded guilty to five counts of sexual exploitation of a child and to being a repeat sex offender. The district court sentenced Barr to five, fifteen-year fixed sentences, to run consecutively to each other, for an aggregate determinate term of seventy-five years, reasoning that section 19-2520G left it no discretion to sentence Barr to anything less severe. On appeal Barr argued the district court abused its discretion when it failed to perceive that it had discretion to: (1) designate indeterminate and determinate portions of the mandatory fifteen-year sentences; and (2) run the sentences concurrently with one another rather than consecutively. Barr also claimed that if the legislature intended section 19-2520G to deprive the court of its traditional power to decide whether to run sentences consecutively or concurrently, the statute is unconstitutional. The Idaho Supreme Court determined Barr’s arguments were not properly preserved for appeal. Therefore, the Court affirmed his conviction and sentence. View "Idaho v. Barr" on Justia Law

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David Glodowski appealed after he was convicted for failing to update his sex-offender registration in violation of Idaho Code section 18-8309. He argued the district court erred by ruling that his prior conviction under a Wisconsin statute was “substantially equivalent” to Idaho statutes that required sex-offender registration in Idaho. After review, the Idaho Supreme Court determined the district court improperly allowed the State to seek a redetermination of the “substantially equivalent” element given that the Idaho Bureau of Criminal Identification made a final determination on that element. However, because the State put forth sufficient evidence to prove that element, and the district court’s jury instruction accomplished the same purpose, the Supreme Court concluded the error was harmless. Accordingly, the Court found no reversible error in the district court’s decision to grant the State’s motion and provide the jury instruction. Therefore, judgment of conviction was affirmed. View "Idaho v. Glodowski" on Justia Law

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Nicholas Blythe appealed after he was convicted of possessing a controlled substance. He conditionally pled guilty, reserving the right to challenge his sentence. On appeal, he argued the district court erred in denying his motion to suppress certain evidence found because the evidence presented at trial was found in violation of Blythe's Fourth Amendment rights. After review, the Idaho Supreme Court determined the search at issue took place before an arrest occurred, and because no rationale justifying a search incident to arrest was sufficiently present here, the search of Blythe’s shoes was not a valid search incident to arrest. Therefore, the district court erred in holding that the search was reasonable under the Fourth Amendment. Blythe's conviction was vacated, the district court order denying Blythe's motion to suppress was reversed, and the matter remanded for further proceedings. View "Idaho v. Blythe" on Justia Law

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Timothy Jones was convicted by jury of trafficking heroin and possession of drug paraphernalia. On appeal, he argued the trial court erred in admitting certain evidence regarding his probation status, a knife found in the initial police search of his person, and that the trial court abused its discretion in arriving at his sentence. Finding no reversible error, the Idaho Supreme Court affirmed Jones' conviction and sentence. View "Idaho v. Jones" on Justia Law