Justia Idaho Supreme Court Opinion Summaries

Desiree Elaine Karst was a passenger in a car stopped by police in Kootenai County, Idaho. During the stop, a drug dog alerted to the presence of drugs, and Karst admitted to having drugs in the car. Additional drugs and paraphernalia were found on her at the jail. She was charged with multiple drug offenses and introducing contraband into a correctional facility. Karst moved to suppress the evidence, arguing the stop was impermissibly extended. The district court partially denied her motion, and Karst entered conditional guilty pleas, reserving her right to appeal. She was ordered to pay $569.50 in various court fees.Karst appealed the partial denial of her motion to suppress. The Idaho Supreme Court found the traffic stop was impermissibly extended, reversed the district court’s decision, and remanded the case. Subsequently, the prosecutor dismissed all charges against Karst. Karst then filed a motion to reimburse the fees she had paid, arguing that retaining her funds violated her due process rights. The district court denied her motion, citing a lack of jurisdiction and suggesting she sue each governmental entity that received the fees.The Idaho Supreme Court reviewed the case and held that the district court had both personal and subject matter jurisdiction to consider Karst’s motion for reimbursement. The court found that the State, by initiating the criminal case, had submitted to the district court’s jurisdiction. The court also determined that requiring Karst to file multiple civil suits to recover the fees would impose more than minimal procedures, violating her due process rights. The court reversed the district court’s decision and remanded the case for further proceedings, instructing that Karst should be reimbursed if she proves she paid the fees and her conviction was invalidated. View "State v. Karst" on Justia Law

Benny Dean Campbell was detained by law enforcement while they were investigating a stolen motorcycle. During the detention, a police trooper discovered heroin and methamphetamine in Campbell's backpack. Campbell was charged with two felony counts for drug trafficking and possession of a controlled substance, and two misdemeanor counts for possession of a controlled substance and possession of drug paraphernalia. Campbell filed a motion to suppress the evidence, arguing that by initially placing him in handcuffs, the trooper converted his detention into an unlawful seizure under the Fourth Amendment to the United States Constitution.The district court agreed that Campbell’s detention was a de facto arrest; however, the court also determined that the evidence was admissible under the attenuation doctrine. After the court denied his motion, Campbell entered into a conditional plea agreement that preserved his right to appeal the denied motion. On appeal, he asked the Supreme Court of the State of Idaho to reject the federal attenuation doctrine because Article I, section 17 of the Idaho Constitution affords him greater protections than the federal standard and is incompatible with Idaho’s more expansive exclusionary rule.The Supreme Court of the State of Idaho affirmed the order of the district court. The court agreed with the district court’s conclusion that the State failed to establish that the use of handcuffs on Campbell was a reasonable precaution for the trooper’s safety. However, the court concluded that while the seizure of Campbell was unreasonable, the inevitable discovery exception to the Fourth Amendment makes suppression improper. The court found that even if handcuffs had never been used, the evidence would have been inevitably discovered whether the trooper had followed either parallel path once the trooper walked into the convenience store. Therefore, the court affirmed the district court’s order denying Campbell’s suppression motion on the alternate theory of inevitable discovery. View "State v. Campbell" on Justia Law

The defendant, Britian Lee Barr, was charged with eleven counts of sexual exploitation of a child for possessing child pornography. Barr had previously been convicted of felony possession of sexually exploitative material in 2011. On the second day of trial, Barr pleaded guilty to five counts of sexual exploitation of a child for possessing child pornography and admitted to being a repeat offender. In exchange for his guilty pleas, the other counts were dismissed. Barr was sentenced to five, fifteen-year fixed sentences to run consecutively, resulting in an aggregate seventy-five-year fixed sentence. The consecutive nature of the sentences was mandated by Idaho Code section 19-2520G(3).Barr appealed the sentence, arguing that the district court abused its discretion by failing to perceive that it had discretion to designate indeterminate portions for the mandatory fifteen-year sentences and that it had discretion to order the sentences be served concurrently. The Supreme Court of the State of Idaho affirmed the decision of the district court because Barr had not preserved his arguments for appeal. Barr returned to the district court and filed a Rule 35(a) motion to correct an illegal sentence. Barr argued that the consecutive sentence requirement in Idaho Code section 19-2520G(3) is unconstitutional because it violates the doctrine of separation of powers by usurping the judiciary’s inherent power to determine whether a sentence runs consecutively or concurrently. The district court denied the motion, concluding that the legislature is empowered to designate mandatory consecutive sentences under the plain language of Article V, section 13 of the Idaho Constitution. Barr timely appealed.The Supreme Court of the State of Idaho held that determining whether a sentence is to be served consecutively or concurrently is not a power reserved exclusively to the judiciary. As a result, section 19-2520G(3) does not violate the separation of powers provision of the Idaho Constitution. The court affirmed the district court's decision denying Barr's Rule 35(a) motion. View "State v. Barr" on Justia Law

In this case, the plaintiffs, BABE VOTE and the League of Women Voters of Idaho, challenged two amendments to Idaho's election laws, House Bills 124 and 340, which modified the forms of identification voters can use to prove their identity when registering to vote and voting at the polls. The plaintiffs argued that the bills violated the Idaho Constitution's guarantee of equal protection and unduly burdened the right of suffrage. The Idaho Secretary of State, Phil McGrane, counterclaimed, seeking a judgment declaring that the bills did not violate these rights under either the Idaho or the United States Constitutions. The district court granted the Secretary’s motions and entered judgment in favor of the Secretary.The Supreme Court of the State of Idaho affirmed the decisions of the district court. The court held that the bills were a valid exercise of the legislature’s power to enact conditions on the right of suffrage under Article VI, section 4 of the Idaho Constitution. The court applied the rational basis test and found that the new laws were rationally related to their stated purpose to clarify and create uniformity by requiring only generally accepted, authentic, and reliable forms of identification as a reasonable condition to exercise the right of suffrage. The court also found that the bills did not violate the Equal Protection Clause of the Idaho Constitution. View "BABE VOTE v. McGrane" on Justia Law

The case involves the defendant, Kevin James Van Zanten, who was convicted for felony possession of methamphetamine and misdemeanor driving under the influence. Van Zanten challenged the conviction, arguing that the evidence was obtained unlawfully following a stop of the commercial vehicle he was driving. He claimed the stop was based on regulations adopted by the Idaho State Police, which he argued resulted from an unconstitutional delegation of legislative power.In September 2020, an Idaho State Police Trooper observed a 2005 Kenworth truck driven by Van Zanten. The Trooper noted several violations, including an improperly displayed Department of Transportation number, unsecured hazardous material, and other items on the truck. The truck was stopped, and the driver was identified as Van Zanten, whose driving privileges were found to be suspended. A subsequent search of the truck resulted in the finding of drugs, leading to Van Zanten's arrest.At the trial court, Van Zanten moved to suppress the evidence, arguing that the Trooper had no legal basis to stop him. He asserted that the Trooper initiated the stop to investigate state regulations that were unenforceable because the statutes authorizing those regulations unconstitutionally delegated legislative power. The district court denied his motion, leading to his appeal to the Idaho Supreme Court.The Supreme Court of the State of Idaho affirmed the district court's judgment. It held that the Trooper had reasonable suspicion to stop Van Zanten due to specific, articulable facts, thus justifying the stop. The court noted that the inherent danger associated with unsecured hazardous waste and other violations fell within the community caretaking function of law enforcement, and given the nature of the vehicle Van Zanten was driving, the public interest in safety outweighed the limited intrusion of stopping the vehicle. Consequently, the court did not need to address the constitutionality of the statutes in question. The court affirmed Van Zanten’s judgment of conviction. View "State v. Van Zanten" on Justia Law

The Supreme Court of the State of Idaho affirmed the dismissal of a successive post-conviction petition for relief filed by Thomas Eugene Creech, an inmate sentenced to death in 1995 for the murder of fellow inmate David Jensen. The district court had dismissed Creech's petition as untimely under Idaho Code section 19-2719, which requires capital defendants to file any legal or factual challenge to the sentence or conviction that is known or reasonably should be known within forty-two days of the filing of the judgment imposing the death sentence. Creech argued that his death sentence, which was imposed by a judge without the participation of a jury, was unlawful based on the prohibition against cruel and unusual punishment under the U.S. Constitution and the Idaho Constitution. He also claimed that societal norms have evolved to the point where his judge-imposed death sentence is now deemed cruel and unusual punishment. However, the Supreme Court held that Creech failed to articulate a claim based on information he did not know or could not have reasonably known within the forty-two day period, thus upholding the district court's dismissal of his petition as untimely. View "Creech v. State" on Justia Law

The Idaho Supreme Court upheld a conviction of a man named Troy Dale Green for various offenses, including trafficking in methamphetamine and unlawful possession of a firearm. Green appealed his conviction, arguing that the testimony of a detective who had not personally performed the extraction of data from his cellphone violated his rights under the Confrontation Clause of the Sixth Amendment. The court disagreed, ruling that the detective's testimony did not violate Green's rights because the detective had sufficient knowledge and experience to analyze the extracted data and independently conclude that the data came from Green's phone. The court also rejected Green's argument that the text messages from his phone were not properly authenticated under Idaho's rules of evidence. The court found that the detective's testimony, along with that of two other detectives, sufficiently authenticated the text messages. The court affirmed Green's conviction. View "State v. Green" on Justia Law

In the case before the Supreme Court of the State of Idaho, defendant William Parsons was convicted on three felony counts of lewd conduct with a minor under sixteen and one misdemeanor count of disseminating harmful material to a minor. The prosecution's case was largely based on video evidence from two interviews with the minor victim, conducted by a medical social worker at a children's evaluation service that specializes in abuse cases. The victim did not testify at the trial. On appeal, Parsons argued that the admission of the video evidence violated his Sixth Amendment rights under the Confrontation Clause, as he was not given an opportunity to confront his accuser.The court agreed with Parsons, concluding that the videos were submitted to the jury in violation of the Sixth Amendment. The court found that the primary purpose of the victim's interviews was to establish or prove past events potentially relevant to a later criminal prosecution, rather than to provide medical care. Therefore, the statements in the interviews were testimonial in nature. Since the defendant had no prior opportunity to cross-examine the victim, the court held that it was error to admit the videos at trial. The court vacated the conviction and remanded the case for further proceedings consistent with its decision. View "State v. Parsons" on Justia Law

In this case, the Idaho State Athletic Commission and the Idaho Division of Occupational and Professional Licenses sought a declaratory ruling that provisions of the Idaho Administrative Procedure Act (APA) requiring legislative approval of pending administrative fee rules violated the Idaho Constitution. They also sought a Writ of Mandamus directing the Office of the Administrative Rules Coordinator to publish the Athletic Commission’s 2022 administrative rules in the Idaho Administrative Code. The Idaho Supreme Court held that it had jurisdiction to consider the case, but dismissed the petition for a declaration of unconstitutionality and denied the petition for a Writ of Mandamus. The court concluded that the APA requirement for legislative approval of pending administrative rules did not violate the Idaho Constitution's separation of powers, enactment, presentment, or administrative rules provisions. In reaching this conclusion, the court emphasized that administrative rulemaking authority was a legislative delegation, not a constitutional power, and that the legislature was free to modify the process by which administrative rules were enacted. View "Idaho State Athletic Commission v. Office of the Administrative Rules Coordinator" on Justia Law

In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees. View "Worthington v. Crazy Thunder" on Justia Law