Justia Idaho Supreme Court Opinion Summaries

In December 2017, Klaus Nico Gomez-Alas was charged with two felony counts: rape and infamous crime against nature. At trial, he was acquitted of rape, but convicted of simple battery as an included offense. On the second count, the jury found Gomez-Alas guilty of an infamous crime against nature. After the verdict, Gomez-Alas moved the district court for a new trial pursuant to Idaho Criminal Rule (I.C.R.) 34, arguing the district court misled the jury by giving an improper “dynamite” instruction. Gomez-Alas also moved the district court for judgment of acquittal on the second count pursuant to I.C.R. 29, arguing there was insufficient evidence to support a conviction for the infamous crime against nature charge. The district court denied both post-trial motions. Gomez-Alas argued on appeal to the Idaho Supreme Court: (1) the act of cunnilingus does not constitute an infamous crime against nature under Idaho Code sections 18-6605 and 18-6606; (2) there was insufficient evidence to support a conviction for the infamous crime against nature charge; and (3) the district court misled the jury by providing an improper dynamite instruction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Gomez-Alas" on Justia Law

In September 2018, Idaho State Police Sergeant Curt Sproat pulled over a vehicle driven by defendant-respondent Cody Hansen on Interstate 90 after observing a traffic infraction. As Sergeant Sproat approached the vehicle on the passenger side, he saw a passenger in the back seat making “furtive movements.” Sergeant Sproat asked Hansen for his license and registration and requested identification from the passengers. Hansen provided his license, but informed Sergeant Sproat that he had not yet registered the vehicle and did not know his home address. He also told Sergeant Sproat that he was on felony probation. Hansen declined to give consent to Sergeant Sproat to search the vehicle. After his conversation with Hansen, Sergeant Sproat attempted to contact Hansen’s probation officer, but she was not available. Unable to get ahold of an on-call probation officer, Sergeant Sproat began drafting a citation. After a discussion with another Idaho State Police trooper, Sergeant Sproat decided to search the vehicle. During the search, Sergeant Sproat found a digital scale, a methamphetamine pipe, and eight “dime” baggies of what appeared to be methamphetamine. Based on the contraband found in the vehicle, Sergeant Sproat arrested Hansen. A grand jury indicted Hansen for possession with intent to deliver a controlled substance in violation of Idaho Code section 37-2732(a)(1)(A). Hansen moved to suppress all evidence found in the vehicle, arguing, among other things, that his vehicle was searched without a warrant in violation of the Fourth Amendment of the United States Constitution and Article I, section 17 of the Idaho Constitution. The State appealed when the district court granted Hansen’s motion to suppress. The district court determined that Hansen effectively revoked the consent to be searched he had given as a condition of his probation. The Idaho Supreme Court reversed, finding Hansen never sought to modify the Fourth Amendment waiver term of his probation agreement with the court that granted him probation. Instead, Hansen refused to provide Sergeant Sproat with consent to search his vehicle during the traffic stop. "Even assuming that Hansen intended to revoke the previously agreed to consent in his probation agreement, such an attempt was ineffective because it was not made in court. Accordingly, we conclude that the district court erred in finding that Hansen revoked the consent to be searched provided for in his probation agreement." View "Idaho v. Hansen" on Justia Law

Nicole Lyn Gneiting appealed her conviction for possession of major contraband within a correctional facility under Idaho Code section 18-2510(3). Police responded to a call to a potential burglary at an Idaho Falls motel. They eventually questioned Gneiting, who said she was not staying there, but visiting a friend who was. Officers found a "hard bulgy object" on Gneiting's upper thigh after a pat down search. The object turned out to be a flashlight. A search of the motel room netted a purse containing marijuana, Xanax and Adderall pills. Gneiting was ultimately placed under arrest and taken to the station. When asked whether she had anything illegal on her person, and after given warnings that if she took anything illegal into the jail, she Gneiting would receive an additional charge. Police suspected Gneiting was still carrying something underneath her clothes; she was strip searched and police found a white paper envelope between Gneiting's legs. The envelope was later determined to contain three small plastic bags totaling over 30 grams of methamphetamine. Gneiting was convicted by a jury after a four-day trial on drug possession charges. On appeal, Gneiting argued the State failed to present sufficient evidence to prove beyond a reasonable doubt that she knowingly possessed contraband within a correctional facility because she did not enter the county jail voluntarily. Finding no reversible error, the Idaho Supreme Court affirmed Gneiting's conviction. View "Idaho v. Gneiting" on Justia Law

A district court granted Michael Bonner's motion to suppress evidence following a traffic stop that lead to his arrest for driving without privileges and for DUI. Bonner argued that the arresting officer lacked a reasonable articulable suspicion that a crime had occurred or was about to occur, and had seized Bonner by taking his identification and ordering him to sit on the curb. The State argued that Bonner had waived his Fourth Amendment rights in his parole agreement, and therefore lacked standing to object to the seizure. Alternatively, the State argued the police officer had made consensual contact with Bonner, and if the instruction for Bonner to sit on the curb constituted a detention, it was a seizure supported by reasonable articulable suspicion of criminal activity. After review, the Idaho Supreme Court concluded the district court erred in ruling that the police officer did not have a reasonable suspicion to detain Bonner. "Accepting the findings of the district court as true, we nonetheless conclude that the totality of the circumstances supports the conclusion that the officer articulated a reasonable basis for suspecting that illegal conduct was taking place. Therefore, while we acknowledge that this is a very close question, we conclude that the district court erred in granting the motion to suppress. In light of this ruling, it is unnecessary to address the State’s alternative theory that the stop was consensual." View "Idaho v. Bonner" on Justia Law

A guardian ad litem (GAL) for two minor children appealed after a magistrate court determined the children should have been placed with their biological father in Mexico. Jane Doe I (Daughter) and John Doe II (Son) were removed from the care of their mother (Mother) along with another half-sibling on after a preliminary investigation revealed the children were homeless and living in a car. At the time Daughter and Son were taken into foster care, the specific whereabouts of their biological father, John Doe (Father), were unknown, other than that he had been deported to Mexico in December 2014. Father had last seen the children at that time. In addition, his paternity had not yet been established and he had not had any contact with his children since his deportation. A little more than a year after the proceedings had begun, Father’s paternity was established. Shortly after the Department filed an amended petition, it sought a case plan for Father. The Department also attempted to obtain a home study for Father but faced difficulty accomplishing this task because he lived in Mexico. The children’s GAL opposed placing the children with Father without more information about him and his living situation. Ultimately, the magistrate court ordered that the children be placed with Father as soon as possible without a home study being conducted, apparently relying on In re Doe, 281 P.3d 95 (2012). On motions to reconsider filed by the Department and the GAL, newly-discovered evidence was presented that Father was a registered sex offender who had previously pleaded guilty to failing to register as such. Nevertheless, the magistrate court denied the motions to reconsider. The GAL appealed. After review, the Idaho Supreme Court reversed the magistrate court, holding that while it continued "to recognize that the biological parent’s presumption of fitness is and should be very strong. However, it is not irrefutable. . . . Where the legislature has unequivocally placed a duty on the court and the Department to consider its primary concern 'the health and safety of the child,' it is incumbent on a court to ensure that diligent investigation occurs regarding questions pertaining to children’s safety." View "IDHW & John Doe v. GAL & 4th Judicial District Casa" on Justia Law

In 2016, John Doe was cited for petit theft. Doe’s disposition hearing was held, and the magistrate court committed Doe to the custody of Idaho Department of Juvenile Corrections (“IDJC”). the magistrate court ordered Doe’s father, Dennis Dudley, to reimburse IDJC for expenses incurred in caring for and treating Doe pursuant to Idaho Code section 20-524(1). Doe and Dudley appealed the reimbursement order to the district court. The district court, acting in its intermediate appellate capacity, affirmed. Doe and Dudley timely appealed the district court’s decision. The Idaho Supreme Court dismissed the appeal, finding the reimbursement order against Dudley was not a final appealable order. View "IDJC v. Dudley" on Justia Law

James Hairston was sentenced to death after a jury convicted him of two counts of first-degree murder in connection with the deaths of William and Dalma Fuhriman. Hairston was about nineteen and a half when he killed the Fuhrimans. In this, his fourth post-conviction petition, Hairston argued his sentence was unconstitutional because: (1) he was under the age of twenty-one at the time of the offense; and (2) the trial court failed to give adequate consideration to the mitigating factors that had to be considered with youthful defendants. The district court dismissed Hairston’s first claim after holding that he failed to show that evolving standards of decency prohibited imposing the death penalty for offenders between the ages of eighteen and twenty-one. The court dismissed Hairston’s second claim after finding that there was no basis to extend the special sentencing considerations that have been specifically limited to juvenile defendants under eighteen to those under twenty-one. Finding no reversible error in those judgments, the Idaho Supreme Court affirmed. View "Hairston v. Idaho" on Justia Law

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

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

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