Justia Idaho Supreme Court Opinion Summaries

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

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

Richard Hess appealed an order of restitution entered against him following his guilty plea to trafficking heroin. Hess relied on the Idaho Supreme Court’s decision in Idaho v. Nelson, 390 P.3d 418 (2017), to argue that there was insufficient evidence to support all but $1,500 of the award. The Court of Appeals reversed the restitution order, and the Supreme Court granted the State’s timely petition for review. The Court determined that $500 of the district court’s award of investigation costs was unsupported by the evidence. However, the district court correctly awarded the remaining amounts of restitution because: (1) Hess failed to preserve his foundational objections; and (2) substantial evidence supported the remainder of the award. View "Idaho v. Hess" on Justia Law

Jesus Manuel Garcia was found guilty by jury of second-degree murder, aggravated battery, use of a deadly weapon during the commission of the former crimes, and possession of a controlled substance. The district court sentenced Garcia to an indeterminate life sentence with twenty-five years fixed for second degree murder, which included a sentencing enhancement for the use of a deadly weapon. The district court also sentenced Garcia to twenty years, with six years fixed, for aggravated battery; this also included a sentencing enhancement for the use of a deadly weapon. The district court further sentenced Garcia to three years fixed for the possession of a controlled substance conviction. All three sentences were ordered to run concurrently. In addition, the district court ordered restitution to the victims in the amount of $162,285.27. Garcia timely appealed, arguing: (1) the district court abused its discretion in allowing the State to present “in-life” photos of the victim and to elicit testimony about the victim’s personality and character during trial; (2) the prosecutor committed misconduct when she referred to this challenged evidence in her closing statement; (3) Garcia was deprived of due process because of the cumulative errors; (4) the district court abused its discretion in imposing a sentence that did not give proper weight and consideration to mitigating factors; and (5) the district court abused its discretion in ordering Garcia to pay restitution without adequately considering his current and future ability to pay restitution. Finding only that the district court abused its discretion in ordering restitution without proper consideration of Garcia's ability to repay the amount in the future, the Idaho Supreme Court affirmed conviction, vacated the restitution order, and remanded for reconsideration of Garcia's foreseeable ability to pay restitution. View "Idaho v. Garcia" on Justia Law

Prior to sentencing, defendant James Burke was committed to the state mental hospital for 56 days to restore him to competency. After being evaluated and deemed competent to proceed to trial, Burke was returned to the county jail and later pleaded guilty pursuant to a plea agreement. At the conclusion of his sentencing hearing, Burke sought credit for the 56 days of time spent in court-ordered commitment. The district court denied the motion, concluding that commitment to a state mental hospital did not fall under the definition of ‘incarceration’ in Idaho Code section 18-309. After reviewing this issue carefully, the Idaho Supreme Court disagreed with the district court’s "thorough and thoughtful analysis," holding that court-ordered commitment to state custody pursuant to Idaho Code sections 18-210 and 18-211 met the functional and legal definition of “incarceration” under Idaho Code section 18-309. "The extent of the liberty interests restricted by Burke’s court-ordered commitment to State Hospital North are just too similar to imprisonment to conclude otherwise." Accordingly, the Court reversed the district court’s order denying Burke’s request for credit for time served and remanded the case for the district court to enter an order crediting him with the fifty-six days he spent committed to State Hospital North while the State restored his competency to face criminal charges. View "Idaho v. Burke" on Justia Law

Riley Lodge appealed a no contact order entered against him as a result of his being convicted of two counts of sexual battery of a minor child sixteen or seventeen years of age. After Lodge pleaded guilty to these two counts, the district court entered a no contact order which prohibited Lodge from having contact with the named victims and “[a]ll minor children.” On appeal, Lodge contended the district court abused its discretion by failing to provide an exception to the no contact order for two minor children who were also his biological children, and who were conceived as a result of the underlying sexual batteries. Lodge argued the district court failed to exercise reason because there was no evidence that he posed a threat to his own children. The Idaho Supreme Court found no abuse of discretion and affirmed the district court and the no contact order. View "Idaho v. Lodge" on Justia Law

Martin Edmo Ish appealed his conviction and sentence for one count of voluntary manslaughter. The State charged Ish with second-degree murder in November 2015 for the June 2009 killing of Eugene Lorne Red Elk in Pocatello, Idaho. Ish and friends were barhopping when at some point, Ish had a confrontation with staff at the Bourbon Barrel. Ish and his friends went a few blocks away to Duffy's Tavern. The friends returned to the Bourbon Barrel, but Ish did not; Barrel staff called Duffy's to alert them of Ish's earlier confrontation. Red Elk was working at Duffy's as a bouncer. He asked Ish to leave, and Ish complied. Later that night, however, Red Elk was discovered in Duffy's parking lot "gurgling blood." He had suffered a brain injury from blunt force trauma to the head; despite being life-flighted to a medical center in Idaho Falls, Red Elk died three days later. TO police, Ish admitted that he “blasted” Red Elk and he “was pretty sure he killed him because he was laying [sic] there gurgling.” A trial was held in April 2017 after which the jury found Ish guilty of the lesser-included charge of voluntary manslaughter. Ish appealed, claiming the trial order erred in seating and instructing the jury, and in making certain evidentiary rulings. After review, the Idaho Supreme Court vacated the judgment of conviction and remand for a new trial. The Supreme Court determined the district court’s finding that the prosecution did not strike Juror 3 with discriminatory intent was clearly erroneous. The Court affirmed the trial court in all other respects. View "Idaho v. Ish" on Justia Law

Michael Hayes was convicted by jury of felony battery on a correctional officer. Hayes appealed his judgment of conviction on three grounds: (1) the district court erred by failing to issue subpoenas for two medical professionals; (2) the district court abused its discretion by allowing the State to inquire into prior instances of Hayes’ conduct towards correctional officers; and (3) the district court abused its discretion by denying Hayes’ motion for a new trial. The Court of Appeals reversed the district court’s order denying Hayes’ requests for subpoenas, and held that the district court abused its discretion by allowing the State to inquire into prior instances of Hayes’ conduct. Accordingly, the Court of Appeals vacated the district court’s judgment of conviction and remanded the case for a new trial. The Idaho Supreme Court granted the State’s petition for review, and finding the district court did not err in issuing its judgment, the Supreme Court reversed the appellate court and affirmed the trial court's judgment of conviction. View "Idaho v. Hayes" on Justia Law

Natalie Shubert sued her former public defender, Michael Lojek, former Ada County chief public defender Alan Trimming, and Ada County (collectively the “Ada County Defendants”). In 2008, Shubert was charged with two felonies and pleaded guilty to both charges. Her sentences were suspended in each case, and she was placed on probation. After a probation violation in 2011, the Ada County district court entered an order extending Shubert’s probation beyond the time period allowed by law. The mistake was not caught. After Shubert’s probation should have ended in both cases, she was charged and incarcerated for a subsequent probation violation in 2014. Thereafter, in 2016, Shubert was charged with a new probation violation. Shubert was assigned a new public defender, who discovered the error that unlawfully kept Shubert on probation. Shubert’s new public defender filed a motion to correct the illegal sentence, raising the error that had improperly extended her probation. The district court granted Shubert’s motion to correct the illegal sentence and released Shubert from custody. Shubert then sued the Ada County Defendants, alleging false imprisonment, intentional infliction of emotional distress, negligence per se, negligence, and state and federal constitutional violations. The district court dismissed all of Shubert’s claims except for negligence. In denying the Ada County Defendants’ motion for summary judgment, the district court held that public defenders were not entitled to common law quasi judicial immunity from civil malpractice liability, and two provisions of the Idaho Tort Claims Act (ITCA) did not exempt public defenders from civil malpractice liability. The Ada County Defendants petitioned the Idaho Supreme Court pursuant to Idaho Appellate Rule 12. Finding no reversible error in the district court's judgment, the Supreme Court affirmed the district court’s order granting summary judgment, and remanded for further proceedings. View "Shubert v. Ada County" on Justia Law

Employers Resource Management Company (“Employers”) returned to the Idaho Supreme Court in a second appeal against the Idaho Department of Commerce. In 2014, the Idaho Legislature passed the Idaho Reimbursement Incentive Act (“IRIA”). The Economic Advisory Council (“EAC”), a body created under IRIA to approve or deny tax credit applications, granted a $6.5 million tax credit to the web-based Illinois corporation Paylocity, a competitor to Employers Resource Management Company. Employers claimed Paylocity’s tax credit created an unfair economic advantage. Paylocity, however, had yet to receive the tax credit because it did not satisfy the conditions in the Tax Reimbursement Incentive agreement. Having established competitor standing in Employers Res. Mgmt. Co. v. Ronk, 405 P.3d 33 (2017), Employers argued the Idaho Reimbursement Incentive Act was unconstitutional under the separation of powers doctrine. The district court dismissed Employers’s case upon finding the Act constitutional. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "Employers Resource Mgmt Co v. Kealy" on Justia Law