Articles Posted in Constitutional Law

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Justin Hoskins appealed a district court’s denial of his motion to suppress. In September 2016, Idaho State Trooper Spencer Knudsen observed a Pontiac Grand Am driving with a cracked windshield and pulled it over. He asked the driver for the vehicle’s registration and insurance as well as identification for the vehicle’s three occupants. The identification revealed that Jovette Archuleta was the driver of the vehicle, Amber Alvarez was seated in the passenger’s seat, and Hoskins was seated alone in the back seat. dispatch informed Trooper Knudsen that the vehicle’s license plates actually belonged to a Chevrolet Malibu registered to Archuleta. Dispatch also notified Trooper Knudsen that all of the vehicles’ occupants had prior drug convictions. Returning to the Pontiac, Trooper Knudsen asked Archuleta to step out of the car to speak with him. Once she had, he questioned her about whether the car contained anything illegal. After she stated that she didn’t believe so, Trooper Knudsen asked for permission to search the car. Alvarez gave her permission to search the vehicle. Before searching the vehicle, Trooper Knudsen directed Hoskins to get out of the backseat, instructing Hoskins to leave his personal items on the backseat. During the search, Trooper Knudsen found marijuana and methamphetamine. Hoskins was arrested and charged with possession of methamphetamine with a sentencing enhancement based on a prior drug conviction. Hoskins promptly filed a motion to suppress the evidence taken from the traffic stop. The State argued Hoskins lacked standing to object to the search based on consent and the district court denied the motion on that basis. On appeal, all parties agreed the district court’s ruling on standing was erroneous. Nevertheless, the State argued the district court’s decision could be affirmed based on the plain-view doctrine. Hoskins objected and argued the State forfeited this argument by failing to raise it below. Hoskins prevailed at the Court of Appeals and the Idaho Supreme Court granted the State’s timely petition for review. The Supreme Court did not consider the State's plain-view argument on appeal because the issue was not preserved for review: "Devising a 'correct' theory for the first time on appeal does not give the State a legal mulligan when it concedes that its original theory did not carry the burden below. The same logic holds true for the State’s argument regarding exceptions to the exclusionary rule." The Court reversed the district court's denial of Hoskins' motion to suppress, vacated his judgment of conviction and remanded the matter for further proceedings. View "Idaho v. Hoskins" on Justia Law

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Byron Sanchez appealed a district court’s judgment of conviction for one count of threats against a public servant. In September 2016, Sanchez was in prison for a felony injury to a child offense arising out of Gem County, Idaho. While incarcerated, Sanchez sent a letter to the Gem County prosecutor that allegedly threatened harm to the prosecutor and his family. Sanchez’s letter prompted the State to charge Sanchez with one count of threats against a public servant with an enhancement because Sanchez committed the offense on the grounds of a correctional facility. A jury convicted Sanchez and he was sentenced to consecutive five-year prison terms, with four years fixed. On appeal, Sanchez challenged the district court’s denial of his pre-trial motion to dismiss as well as several evidentiary rulings by the district court. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Sanchez" on Justia Law

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Defendant-appellant Mark Garnett was an overnight guest in the residence of an absconded felony probationer. Probation officers searched the residence, including an attached storage room, and found Garnett’s locked backpack containing a stolen firearm. Garnett, a felon himself, was arrested and charged with unlawful possession of a firearm. He sought to suppress the evidence found in the backpack, but the district court denied his motion because it determined that while he had standing to challenge the search of the backpack, the officer had reasonable suspicion that the absconded probationer owned, possessed, or controlled the backpack. Following a jury trial, Garnett was found guilty. Garnett appealed his conviction, arguing that the district court should have applied a reasonable belief standard and that had it done so the motion to suppress would have been granted. The Idaho Supreme Court disagreed with that reasoning, and finding no other reversible error, affirmed the district court’s decision and the judgment of conviction. View "Idaho v. Garnett" on Justia Law

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The State appealed a district court order granting Isaac Saldivar’s motion to suppress evidence that he unlawfully possessed a firearm. During a pat-search, police discovered a Smith & Wesson semi-automatic pistol in the left front pocket of Saldivar’s pants. The police later learned that Saldivar was a parolee who was wanted on an active warrant. The district court determined that the officers lacked reasonable suspicion to conduct the pat-search. The district court further held that the inevitable discovery exception was inapplicable to the facts of this case and granted the motion to suppress. The State argued the search was reasonable under the circumstances, and that even if it was not, the inevitable discovery exception applied to this case. It also argued that because of his parole status, Saldivar did not retain a reasonable expectation of privacy regarding the pat-search. The Idaho Supreme Court concluded the search was reasonable under the circumstances presented to the trial court and reversed that court’s suppression order. View "Idaho v. Saldivar" on Justia Law

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Relying on Idaho Criminal Rule 47, Jane Doe filed a motion to modify disposition requesting that the juvenile court place her back on probation after sentence had been imposed, and modify its previous computation of credit for time served. The juvenile court held that Doe’s motion was actually a motion to reduce sentence under Idaho Criminal Rule 35 (a rule which has not been incorporated into the Idaho Juvenile Rules) and concluded that it did not have jurisdiction to consider Doe’s motion. Doe appealed the juvenile court’s decision to the district court. The district court affirmed the decision, holding that Rule 47 did not grant jurisdiction to reduce the sentence, but that jurisdiction existed under Idaho Code sections 20-505 and 20-507. The district court held that whether the sentence should be modified was a discretionary call and that the juvenile court did not abuse its discretion in declining to place Doe back on probation or incorrectly calculate Doe’s credit for time served. The Idaho Supreme Court agreed with the district court’s decision to affirm the magistrate court’s denial of Doe’s motion to modify disposition, but took the opportunity to explain there was no jurisdiction for the juvenile court to modify the juvenile’s sentence once it had been imposed and the time for appeal had run. View "Idaho v. Jane Doe (Juvenile)" on Justia Law

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Darryl Joe Albertson appealed his conviction for possession of a controlled substance. In August 2016, a police officer approached Albertson’s front door and observed through a window that he was smoking methamphetamine. Because he had a “no trespassing” sign posted near the opening to his property, Albertson argued the officer’s conduct constituted an unreasonable search under the Fourth Amendment to the United States Constitution and Article I, section 17 of the Idaho Constitution. Consequently, he asked the Idaho Supreme Court to reverse the district court’s decision denying his motion to suppress the evidence. The State argued the "no trespassing" sign in question was insufficient to revoke the implied license for uninvited visitors to approach his home. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Albertson" on Justia Law

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Richard Wilson was convicted of two counts of aiding and abetting trafficking in methamphetamine. He appealed on grounds that the State failed to present sufficient evidence to support either conviction. Finding the State provided substantial evidence for the jury to conclude beyond a reasonable doubt Wilson aided or abetted in the trafficking of what was represented to be 28 grams or more of methamphetamine, the Idaho Supreme Court affirmed the judgment of conviction on both counts. View "Idaho v. Wilson" on Justia Law

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Jason Godwin, Sr. appealed after he was convicted for the second degree murder of Kyle Anderson in 2014. In his appeal, Godwin argued district court erred: (1) by denying his motion to suppress evidence of statements he made to police; (2) by requiring him to show personal knowledge of Anderson’s violent or aggressive character before allowing him to present evidence of that character; and (3) by failing to properly instruct the jury on justifiable homicide under section 18-4009 of the Idaho Code. Godwin also argued the State committed prosecutorial misconduct by impermissibly vouching for evidence and witnesses in closing arguments. Godwin asserted the complained-of errors in his case, even if harmless individually, amounted to a due process violation when viewed cumulatively. Finding no reversible error, the Idaho Supreme Court affirmed his conviction. View "Idaho v. Godwin, Sr." on Justia Law

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Jeffrey Jeske appealed his conviction of felony driving under the influence (DUI), contending the district court erred: (1) when it allowed the deputy prosecutor to comment on his refusal to consent to a blood draw to test it for alcohol; (2) when it allowed regarding testimony of uncharged misconduct; and (3) when it allowed the State to amend the charges against him the morning of the trial and in refusing to give a requested jury instruction. Jeske claimed the cumulative error doctrine required his conviction to be vacated. Rejecting these contentions, and finding no reversible error, the Idaho Supreme Court affirmed Jeske's conviction. View "Idaho v. Jeske" on Justia Law

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Matthew Abramowski was charged with, and ultimately pled guilty to, first degree arson when he was 15 years old. He was charged as an adult, but received a blended sentence which gave the Department of Juvenile Corrections jurisdiction over Abramowski while he was a juvenile. The district court withheld judgment and eventually dismissed the case. After the dismissal, Abramowski filed a motion to seal the case pursuant to Rule 32(i) of the Idaho Court Administrative Rules. At the motion hearing, the district court realized that Abramowski was not just asking that his record be sealed, but that all traces of the case on the court’s repository be erased from public view. The district court entered an order sealing Abramowski’s record up through the age of twenty-one but instructed Abramowski to file a motion to expunge the record to give the State an opportunity to respond to his request. Abramowski filed a motion to expunge and was given a hearing, but the district court denied his request for expungement, determining that the public interest in knowing of Abramowski’s serious charge predominated over his privacy interests. Abramowski then filed a motion to reconsider and presented witnesses at the reconsideration hearing, but the district court again determined the public interest predominated over his privacy interests. Abramowski appealed, arguing that the district court abused its discretion. Finding the district court did not abuse its discretion, the Idaho Supreme Court affirmed the judgment. View "Idaho v. Abramowski" on Justia Law