Justia Idaho Supreme Court Opinion Summaries

Thomas Hooley appealed a district court’s decision to dismiss his pro se filing entitled “Motion For New Trial Based on Evidence withheld in violation of Brady with attached exhibits in support of motion.” In July 2014, a jury convicted Hooley of first-degree kidnapping and aiding and abetting aggravated battery. Hooley unsuccessfully appealed his conviction to the Court of Appeals. The Idaho Supreme Court denied his petition for review and issued a remittitur on December 18, 2015. In May 2018, Hooley lodged a pro se filing with the district court. Almost 200 pages in length, the first pages of the filing were a “sparse” legal template on which Hooley handwrote information. In the substantive portion of the motion, Hooley wrote that a “New Trial motion based on evidence withheld in violation of Brady cannot be denied on basis that new trial would not have produced different outcome and such violations not subject to harmless error analysis.” He also included statements of law and citations. The district court treated the filing as an untimely motion for a new trial based on newly discovered evidence under Idaho Criminal Rule 34. The district court denied the motion as untimely, reasoning that Hooley’s motion was filed outside of the 2-year time constraint on Rule 34 motions because his underlying judgment of conviction became final on December 18, 2015, when the remittitur was issued. Hooley appealed and argued that the district court should have construed his filing as a petition for post-conviction relief. The Court of Appeals affirmed. After granting Hooley’s timely petition for review, the Idaho Supreme Court concurred with the district court and affirmed its order. View "Idaho v. Hooley" on Justia Law

Dave Christensen was indicted by a grand jury on five counts of lewd conduct with two minors under sixteen. The State notified Christensen of its intent to introduce interviews of the two alleged victims at trial under Idaho Rules of Evidence (“I.R.E.”) 803(4) and 803(24). At a pretrial hearing, the district court ruled the interviews were admissible because the victims’ statements were made for purposes of medical diagnosis or treatment. The interviews were admitted at trial by stipulation. A jury found Christensen guilty on four of the five counts. Christensen appealed the district court’s admission of the interviews. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Christensen" on Justia Law

Jeffrey Marsalis appealed a district court’s decision summarily dismissing his petition for post-conviction relief from his 2009 rape conviction. Marsalis alleged that his trial counsel was ineffective for failing to: (1) challenge the testimony of the State’s expert witness regarding his and the victim’s blood alcohol levels; (2) present favorable eyewitness testimony at trial; and (3) properly advise him of his speedy trial rights under the Interstate Agreement on Detainers (IAD). After review, the Idaho Supreme Court reversed in part, and affirmed in part the district court's decision. The Court affirmed the district court’s summary dismissal of Marsalis’s claim that trial counsel was ineffective for failing to call an allegedly favorable eyewitness at trial. However, it reversed and remanded the case for an evidentiary hearing on Marsalis’s claim that trial counsel was ineffective for failing to challenge the underlying methodologies supporting the State’s expert witness’s testimony and for failing to present an expert witness to discuss the scientific basis behind Marsalis’s blackout defense. The Court also remanded the case back to the district court so it could provide Marsalis with twenty days’ notice to respond to the court’s grounds for dismissing Marsalis’s claim that trial counsel was ineffective for failing to inform him of his speedy trial rights under the IAD. View "Marsalis v. Idaho" on Justia Law

Glen Ward appealed an order and final judgment of the district court granting the State’s motion for summary dismissal and dismissing his petition for post-conviction relief. In 2014, Ward was convicted of sexual abuse of a minor under 16 years of age after he pleaded guilty to all elements of the crime except for the sexual intent element, to which he entered an Alford plea. He was sentenced to 18 years imprisonment with a 7-year fixed term. Ward asked for, and was granted, appointment of counsel to represent him in the post-conviction relief proceedings. After granting the motion, the district court appointed a conflict public defender to represent Ward in the action. Although he had secured new counsel, Ward subsequently filed numerous pro se documents. Ward argued the district court abused its discretion by denying his motion to proceed pro se as moot. Ward also argued the district court erred in denying his motion to proceed pro se because a post-conviction petitioner has a right to proceed pro se. After review, the Idaho Supreme Court vacated in part and affirmed. The Court held that the district court should have refused to entertain Ward’s independent filings in the first place; to the extent that the district court entertained the filings made by Ward as opposed to by his attorney, it was error to do so. However, having come to the conclusion that the district court erred, not by ruling incorrectly on Ward’s purported motion, but by ruling on it at all, the Supreme Court did not need to reverse the district court’s separate order and final judgment granting summary dismissal. "Because we hold that there was no motion properly before the district court to be ruled upon in the first place, the district court’s denial of the purported motion has no impact on the propriety of its final decision and judgment dismissing Ward’s post-conviction petition on the merits." View "Ward v. Idaho" on Justia Law

In 2011, a district court granted Aaron Roth a temporary furlough while he was in jail for a probation violation. Under the furlough order, Roth was released from custody. Roth failed to return. In 2017, six years after he absconded, Roth was arrested and later charged with escape, a felony under Idaho Code section 18-2505. A jury found Roth guilty of escape. Roth then moved the district court for a judgment of acquittal under Idaho Criminal Rule (“I.C.R.”) 29, or in the alternative, to dismiss pursuant to I.C.R. 48(a)(2). The district court granted the motion to dismiss under I.C.R. 48(a)(2). The State appealed the district court’s dismissal. After review, the Idaho Supreme Court concluded the district court abused its discretion by dismissing Roth's case. "This ruling extended the reach of due process too far. ... Due process is not a rigid standard and is satisfied when a defendant is provided notice and an opportunity to be heard. Roth had his opportunity to be heard and was sufficiently notified of the furlough order’s requirements to satisfy due process based on the district court explaining the details of the furlough order on the record at the arraignment hearing. The fact, as found by the district court, that Roth did not receive a written copy of the furlough order does not vitiate the notice that Roth had received in court from the judge." The Supreme Court reversed dismissal and remanded for further proceedings. View "Idaho v. Roth" on Justia Law

The State appealed a district court decision to grant defendant David Pool’s motion to suppress the results of a warrantless blood draw on the grounds that it was an unreasonable search under the Fourth Amendment to the U.S. Constitution. In 2016, a police officer came upon the scene of an automobile accident involving two vehicles, one of which was driven by Pool. Pool had failed to negotiate a turn and his vehicle was hit by oncoming traffic. He was not wearing a seatbelt and his airbag deployed in the crash. As a result, he sustained a head injury and was unconscious when the officer arrived at the scene. Pool’s son, a passenger in the vehicle, informed the officer that Pool had not been staying in his traffic lane prior to the crash. He also asserted that the doctors who had prescribed medication to Pool never told him that he could not drive while taking his medications. When Pool regained consciousness, the officer questioned him and noted that he appeared “very lethargic” and “had a presentation similar to a drunk driver . . . slurred speech and thick tongue and obviously disoriented.” Pool told the officer that he believed he had taken his prescription medications that day. Shortly thereafter, a large “baggy” containing seven bottles of prescription medication was recovered from Pool’s vehicle. The officer recognized several of the medications and suspected that they had caused Pool to be impaired. Around that time, Pool and his son were taken to the hospital. The officer followed to question Pool further. At the hospital, the officer ruled out alcohol as a cause of Pool’s impairment based upon the results of a horizontal gaze nystagmus test. The officer did not conduct other field sobriety tests, as he believed Pool’s medical condition rendered it improper for him to do so. Instead, he obtained a blood sample to be used for evidentiary testing. The issue this appeal presented for the Idaho Supreme Court's review centered on the officer’s justification for obtaining the blood sample without a warrant. The State maintained that pursuant to Idaho’s implied consent law, I.C. 18-8002(1), the search was reasonable and the district court erred in requiring proof of exigency. The Supreme Court concurred and reversed the district court. View "Idaho v. Pool" on Justia Law

Shane Lee Dobbs appealed his conviction and the resulting sentence imposed after he pled guilty of lewd conduct with a minor under sixteen. On appeal, Dobbs contended the district court abused its discretion in fashioning a sentence based in part on a desire to “deter[ ] private vengeance” against him. Dobbs also contended his unified sentence of twenty-two years, with ten years fixed, was excessive in light of the mitigating factors. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed Dobbs’ judgment of conviction and sentence. View "Idaho v. Dobbs" on Justia Law

This appeal stems from a criminal defense attorney’s failure to adequately advise his client about the client’s constitutional rights against self-incrimination during a related civil deposition. Melvin Savage was convicted of first-degree arson and misdemeanor stalking. He filed a petition for post-conviction relief claiming that his trial counsel failed to adequately advise him about his rights under the Fifth Amendment of the U.S. Constitution and Article I Section 13 of the Idaho Constitution during a deposition in the civil case initiated by the victims of the arson. The district court granted the State’s motion for summary dismissal of the post-conviction petition. Savage then filed a pro se motion for relief from judgment under Idaho Rule of Civil Procedure 60(b) which was not considered. Savage then timely appealed the district court’s grant of summary dismissal and its order refusing to consider his Rule 60(b) motion. The Idaho Supreme Court determined the district court erred in summarily dismissing Savage’s petition for post-conviction relief because Savage raised a genuine issue of material fact regarding his counsel’s deficient performance. Therefore, the Court reversed the district court’s decision granting the State’s motion for summary dismissal. View "Savage v. Idaho" on Justia Law

In November 2016, Officer Kuebler and Officer Johnson from the Idaho Department of Correction performed a routine residence check on parolee Terry Wilson. Upon their arrival, the officers knocked on the apartment door and Wilson answered. As the officers entered, they noticed Kari Phipps exit from a back bedroom. The officers recognized Phipps from previous visits. The officers asked Phipps and Wilson to take a seat in the living room while they “cleared the bedrooms for other persons.” Officer Johnson testified that, although Phipps never asked to leave at that time, she was not “cleared to leave. . . . [b]ecause of procedure.” After ensuring there was no one else in the apartment, Officer Kuebler advised Phipps and Wilson that a drug dog would be brought in to aid in the search of the residence and asked whether there was anything in the apartment that they should know about. Phipps confessed to having a methamphetamine pipe in her backpack, which was on her person. Officer Kuebler proceeded to conduct a full search of the residence and found two safes containing drugs underneath a bed in a back bedroom. The officers called backup law enforcement to handle the drugs. At some point prior to the arrival of backup, the officers ascertained that Phipps had no outstanding warrants. Approximately ten to twenty minutes later, Officer Hutchison from the Coeur d’Alene Police Department arrived. Officer Hutchison talked with Phipps separately in a back bedroom after he read Phipps her Miranda rights. When asked whether she had a methamphetamine pipe in her backpack, Phipps confirmed that she did. Officer Hutchison searched Phipps’s backpack and found the methamphetamine pipe. Consequently, Officer Hutchison issued Phipps a citation for possession of drug paraphernalia. Phipps asserted the statements she made while detained during a routine parole search of a parolee’s residence, along with the evidence found as a result of her statements, were inadmissible on Fourth Amendment grounds. The State appealed, seeking to delineate the authority of parole officers to detain a non-parolee while performing a routine parole search of a parolee’s residence. The Idaho Supreme Court determined the limited detention of Phipps was reasonable, thus the district court erred in reversing the magistrate court's order denying Phipps' motion to suppress. The magistrate court's order was reinstated and the matter remanded for further proceedings. View "Idaho v. Phipps" on Justia Law

Andrew Maxim was charged with felony possession of a controlled substance. He appealed the district court’s denial of his motion to suppress drug evidence found on his person after police searched the home he was living in without a warrant. The district court found that the exclusionary rule need not apply under the circumstances because the police would have inevitably discovered the heroin despite any alleged illegality. The dispositive issues on appeal were whether a probationer could object to a search of his home or person when he waived his Fourth Amendment rights as a condition of probation and whether the district court erred in its inevitable-discovery analysis. After review, the Idaho Supreme Court reversed, holding that a Fourth Amendment waiver which is unknown to an officer at the time of a Fourth Amendment violation could not be relied on to assert that the search was reasonable. The Supreme Court also determined the district court misapplied the inevitable discovery doctrine by engaging in a speculative analysis that did not rely on an investigative path set in motion prior to or independent of the unlawful police activity. The district court’s judgment of conviction was vacated, the denial of Maxim’s motion to suppress was reversed, and the matter remanded for further proceedings. View "Idaho v. Maxim" on Justia Law