Justia Idaho Supreme Court Opinion Summaries

Katherine Lea Stanfield appealed a district court summarily dismissing her petition for post-conviction relief. Stanfield was a daycare provider with decades of experience caring for young children. In 2009, she was caring for her two grandsons and W.F., the two-year-old son of her daughter’s boyfriend. W.F. collapsed while in Stanfield’s care and was rushed to a hospital emergency room. Two days later, he was taken off life support and died. Stanfield’s daughter had personally observed W.F.’s father commit acts of abuse on W.F. She informed Stanfield’s lawyers of her observations. In addition, W.F.’s mother informed a police investigator that she had also witnessed W.F.’s father abuse him and implored the authorities to investigate him. However, Stanfield’s attorneys never elicited this evidence at trial. Nevertheless, in 2012, a jury found Stanfield guilty of first-degree murder committed through the aggravated battery and death of a child under twelve years old. Stanfield maintained her lawyers were ineffective in their failure to present that potentially exculpatory evidence. On appeal, Stanfield argued the district court erred in not granting her an evidentiary hearing on four of her claims. Because there were genuine issues of material fact presented in Stanfield’s petition, the Idaho Supreme Court vacated the district court’s summary dismissal and remanded so that Stanfield could be afforded an evidentiary hearing to determine whether her lawyers at trial were ineffective. View "Stanfield v. Idaho" on Justia Law

Jacob Davis appealed a district court’s denial of his motion for a new trial. Following his convictions in two separate cases, and subsequent appeals, Davis moved for a new trial in both cases based on two grounds: (1) the verdicts were contrary to the law or the evidence; and (2) newly discovered evidence. Under the newly discovered evidence claim, Davis claimed the State failed to preserve exculpatory evidence on Facebook, thereby allowing the evidence to be destroyed. The district court denied both motions. On appeal to the Idaho Supreme Court, Davis argued the district court abused its discretion by not applying the proper standard to his newly discovered evidence claim, and that application of the proper standard would have yielded the opposite result. Davis further argued that as a result of this abuse of discretion, his right to a fair trial was violated. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Davis" on Justia Law

The named plaintiff, Mike Zeyen sought declaratory relief and recovery of damages from Pocatello/Chubbuck School District No. 25 on behalf of all students currently enrolled in the district and their guardians. Zeyen alleged that School District 25’s practice of charging fees violated Article IX, section 1, of the Idaho Constitution. Zeyen first sought to certify the class to include all students within School District 25. Zeyen’s later motion to amend sought to add a takings claim under both the Idaho and U.S. Constitutions. The district court denied Zeyen’s motion for class certification based on lack of standing and denied his motion to amend both as untimely and prejudicial to School District 25. The Idaho Supreme Court determined Zeyen failed to show that the district court abused its discretion by denying his second motion for leave to amend the complaint. Furthermore, the Court determined Zeyen lacked standing to bring his class action suit. The Court therefore affirmed the district court's denial of Zeyen's motion to certify the class and denial of his motion for leave to amend the first amended complaint. View "Zeyen v. Pocatello/Chubbuck School Dist 25" on Justia Law

Gilbert Gonzales, Jr., appealed the district court’s order denying his motion to suppress evidence obtained following a warrantless seizure. Gonzales was arrested and charged with possession of methamphetamine and introducing or attempting to introduce methamphetamine into a correctional facility. Gonzales moved to suppress, asserting the warrantless seizure was without legal justification and the evidence obtained was fruit of that illegality. The district court denied the motion after finding the seizure was lawful. The Court of Appeals reversed the district court’s order denying the motion to suppress. The Idaho Supreme Court granted the State’s petition for review and reversed the district court’s order denying Gonzales’ motion to suppress and vacate the judgment of conviction. The Supreme Court determined, based on a review of the record, police lacked a reasonable, articulable suspicion to seize Gonzales. View "Idaho v. Gonzales, Jr." on Justia Law

Jesse Keeton appealed a district court’s order denying him credit for time served. In 2018, Keeton was in custody for thirty-two days following his arrest for driving under the influence of alcohol. The district court dismissed the case without prejudice because the State made a charging error. A few weeks later, the State refiled the case, charging Keeton with the same offense but under a different case number. After Keeton was sentenced, he requested credit for time served. The district court denied his request because Keeton did not have a sentence imposed in the dismissed case and he was not incarcerated before judgment was entered in the refiled case. On appeal, Keeton argued Idaho Code section 18-309, the credit for time served statute, mandated an award of credit when a case involving the same offense was dismissed and later refiled. The Idaho Supreme Court agreed and reversed the district court. View "Idaho v. Keeton" on Justia Law

Upon belief Coleton Sessions was selling tainted marijuana that had caused adverse medical symptoms to its users, police officers arrived at and entered Sessions’ house, and seized illegal substances and paraphernalia. Sessions was arrested and charged with multiple criminal offenses. He moved to suppress the evidence seized by the officers because it was procured without a warrant in violation of his constitutional rights. Based on the information that the officers had at the time they entered the home, the district court determined it was not reasonable for officers to believe that anyone inside the home was in need of immediate medical assistance and granted Sessions’ motion to suppress. The State appealed, arguing the warrantless entry and search were justified because of exigent circumstances. The Idaho Supreme Court determined that because the district court’s conclusions were supported by substantial and competent evidence, it affirmed the district court’s order granting the motion to suppress. View "Idaho v. Sessions" on Justia Law

This case involved a question regarding the proper amount of credit for time served to which Christopher Osborn was entitled under Idaho Code section 19-2603, the statute governing rearrest for a probation violation. Osborn violated a no contact order twice, pleaded guilty to the misdemeanor charges, and was given consecutive sentences of 365 days in jail on each count. Both sentences were suspended and he was placed on probation for two years on each count to be served concurrently. He was later arrested for, and admitted to, violating the terms of his probation; he served 106 days in jail from the date of his arrest before admitting the violations. The magistrate court granted Osborn 106 days credit for time served against the first of his consecutive sentences. Osborn then filed a Rule 35 motion seeking credit for time served against both consecutive sentences. The magistrate court denied Osborn’s motion. Osborn appealed to the district court, and it reversed the magistrate court’s denial and granted Osborn credit for time served against both sentences. The State appealed, but finding no error in the district court’s calculation, the Idaho Supreme Court affirmed. View "Idaho v. Osborn" on Justia Law

Eldon Samuel III appealed after a jury found him guilty of second degree murder for killing his father and first degree murder for killing his brother. Samuel’s younger brother was severely autistic and required significant attention. Both of Samuel’s parents had prescription drug addictions which led to financial problems, criminal charges, and arrests. Throughout Samuel’s childhood the family lived in shoddy, cockroach-infested residences and moved frequently, usually after they had been evicted for not paying rent. Samuel’s mother started abusing pain pills following a car accident when Samuel was 4, became suicidal, and was hospitalized several times. Samuel’s father became addicted to pain pills after he injured his shoulder at work. Samuel’s father began to believe that a “zombie apocalypse” was inevitable. Samuel’s mother testified that Samuel’s father taught him how to kill zombies by playing violent video games, watching zombie themed movies, and training Samuel to use knives and guns. In 2014, officers responded to a 911 call at the Samuel residence that the father had been shot. Samuel would give officers a different version of events that night. Samuel’s father was on medication when he shot a .45 gun outside, believing that a “zombie apocalypse” had begun. Samuel told his father to go back inside. Once his father went inside he pushed Samuel in the chest and told him to leave. Samuel picked up his father’s gun, and when his father pushed him a second time, Samuel shot him in the stomach. Samuel’s father then crawled to Samuel’s brother’s room, leaving a trail of blood on the floor. Samuel did not believe the first shot killed his father and shot him three more times in the head once he reached Samuel’s brother’s room. Samuel got a shotgun and shot his brother while he was under the bed. Samuel reloaded the shotgun and continued to shoot his brother. Samuel then dropped the shotgun and started to stab at his brother with a knife. Samuel moved the mattress off of the bed frame and got a machete. Samuel swung the machete at his brother through the gaps in the wood planks of the bed frame. When his brother tried to climb out from underneath the bed, Samuel hit him in the back of the head with the machete. Samuel continued to swing the machete as hard as he could until his brother stopped talking and was quiet. At that point, Samuel called 911. Originally, the State charged Samuel with two counts of first degree murder. However, after a preliminary hearing, the magistrate court found the State had not established probable cause on the premeditation element for the murder of Samuel’s father. Thus, Samuel was charged with first degree murder for his brother and second degree murder for his father. Samuel challenged the district court’s refusal to suppress certain statements he made to police. He also challenged the sufficiency of the evidence presented against him at trial. Finding these challenges unpersuasive, the Idaho Supreme Court affirmed conviction. View "Idaho v. Samuel" on Justia Law

This appeal came from a district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” Picatti contended Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers (I.C. § 18-705), and aggravated battery on law enforcement. Ultimately, Picatti was convicted, accepting a plea agreement to disturbing the peace and failure to obey a traffic sign. Two years later, Picatti brought his 42 U.S.C. 1983 suit, claiming he was deprived of his rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the deputies, holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. The Idaho Supreme Court affirmed summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

Gary Partee was convicted by jury of delivery of methamphetamine, possession of methamphetamine with the intent to deliver, and possession of methamphetamine. Before trial, Partee moved to exclude statements he made to law enforcement officers during an interview in which he admitted multiple deliveries of methamphetamine that were made as result of a confidential informant agreement. The district court denied his motion. Because the Idaho Supreme Court held the agreement was ambiguous, it vacated the portion of the judgment of conviction for delivery of methamphetamine and vacated the order denying the motion in limine. The case was remanded for further proceedings. View "Idaho v. Partee" on Justia Law