Justia Idaho Supreme Court Opinion Summaries

Defendant-appellant Kirk Charlson appealed after he was convicted for felony driving under the influence. Before the trial, Charlson filed a motion to suppress the results of an evidentiary blood draw that was conducted without a warrant. The district court denied the motion, and Charlson was convicted. On appeal of the denial of his motion to suppress the results of the evidentiary blood draw, Charlson argued the draw violated his Fourth Amendment rights. When the totality of the circumstances in this case were considered, the Supreme Court concluded the State established voluntary consent to evidentiary testing sufficient to obviate the need for a warrant to draw Charlson’s blood. Although the district court did not have the benefit of the Supreme Court’s recent relevant opinions, it nonetheless reached the correct result. Therefore, its order denying Charlson’s motion to suppress the evidence against him was affirmed. View "Idaho v. Charlson" on Justia Law

A jury convicted Mark Lankford on two counts of felony murder for the 1983 murders of Robert and Cheryl Bravance, for which he received the death penalty. The United States Supreme Court overturned the sentence after it found that the State of Idaho failed to give notice that the death penalty could have been imposed in his case. Lankford was retried and again found guilty, and was sentenced to two life sentences. The district court denied Lankford’s first and second motions for new trial. Lankford timely appealed the denial of his motions for new trial. Lankford also filed a pro se Rule 35 motion for correction of an illegal sentence which the district court found to be untimely. Lankford argued to the Idaho Supreme Court that the district court erred in multiple ways and that he was entitled to another new trial. The State argued that Lankford failed to prove that reversible error was committed by the district court and that Lankford’s convictions should be affirmed. After review of the district court record, the Idaho Supreme Court concluded that the prosecutor in Lankford's case engaged in prosecutorial misconduct such that a new trial was warranted. Accordingly, the Supreme Court vacated the district court's judgment and remanded for a new trial. View "Idaho v. Lankford" on Justia Law

Plaintiff-appellant Barry Searcy was an inmate in the custody of the Idaho Department of Correction (IDOC). In 2011, he filed a civil complaint naming as defendants the Idaho State Board of Correction, IDOC, and various individual defendants in their official capacities (collectively “the Board”). Searcy’s complaint alleged that the Board illegally charged inmates fees for: (1) commissary goods; (2) telephone calls; (3) photocopying; (4) medical service co-pays; and (5) hobby supplies. The Legislature had not provided express statutory authorization for any of these fees at the time that Searcy brought this action. Instead, the fees were imposed based upon IDOC policy or Standard Operating Procedures (SOPs). The Board moved for summary judgment in all claims, and the district court ultimately granted the Board's motion. Searcy appealed, and his claims “solely challenging the district court’s grant of summary judgment as to Count I” (alleging that raising revenue through the disputed fees exceeded the Board’s rulemaking authority under Idaho Code section 20-212 and caused a wrongful forfeiture of property in violation of Idaho Code section 18-314) were heard by the Court of Appeals. In a split decision, the Court of Appeals affirmed. Searcy petitioned for review, which the Supreme Court granted. After review, the Court determined that the fees at issue here were not unconstitutional fees. As such, it affirmed the Court of Appeals' judgment. View "Searcy v. Idaho Bd of Correction" on Justia Law

In 2013, 44-year-old defendant Marcos Jimenez was at his girlfriend’s apartment after she had gone to work leaving him to care for her 17-year-old daughter, who had the mental capacity of a 10-year-old and a learning disability. Defendant had told the daughter that he would take her to town to buy her a computer, but first she had to take a shower. While she was doing so, he removed her clothing from the bathroom. When she emerged, he forced himself on the girl. Defendant was charged with sexual battery of a child seventeen years of age and rape. Pursuant to a plea bargain, he pled guilty to the sexual battery charge, and the State dismissed the rape charge. The court sentenced Defendant to eighteen years in the custody of the Idaho Board of Correction with three years fixed followed by an indeterminate period of fifteen years. The court also imposed a fine of $5,000 and a fine of $5,000 that is payable to the girl and her mother. Defendant was also required to register as a sex offender for the rest of his life. Defendant timely appealed. He contends that the court violated his Fifth Amendment rights because it drew adverse inferences from his refusal to submit to a psychosexual evaluation. Finding no violation of defendant's Fifth Amendment rights, the Idaho Supreme Court affirmed defendant's conviction and sentence. View "Idaho v. Jimenez" on Justia Law

In 2010, defendant William Dee Van Komen, Jr. was sentenced to five years in the custody of the Idaho Board of Correction, with the first two years fixed and the remaining three years indeterminate, for possession of marijuana with the intent to deliver. The court retained jurisdiction over the case for 180 days. Prior to the termination of the period of retained jurisdiction, the trial court had the discretion to suspend the sentence and place the defendant on probation. If the period of retained jurisdiction expired without the court affirmatively suspending the sentence and placing the defendant on probation, the court loses jurisdiction, and the defendant remains committed to the custody of the Board of Correction. In this case, the district court held a “rider-review” hearing to determine whether to suspend defendant’s sentence. The Department and the prosecutor recommended that defendant be placed on probation. The court agreed, and it suspended defendant’s sentence and placed him on probation for a period of five years. Defendant later admitted violating the terms of his probation, and in 2013, the court entered an order continuing defendant on probation with an additional term that he successfully complete a specified rehabilitation program. At the arraignment on the alleged probation violations, defendant admitted two, and a third alleged violation was withdrawn. The district court revoked defendant’s probation, but again retained jurisdiction, this time for 365 days. The court again held a rider-review in 2014, and at the conclusion, it was again recommended defendant be placed on probation. The district court then brought up the failure of Defendant to have a polygraph examination “to assess the truthfulness as to, one, no drugs or alcohol after March 28th, 2013, and the extent of sexual activity with [the sixteen-year-old girl].” Defense counsel told the court that he would advise Defendant to assert his Fifth Amendment rights with respect to his involvement with the girl because that could lead to additional charges. The court then ordered that it would relinquish jurisdiction and have Defendant serve the prison sentence because he had not had a polygraph test. The Court of Appeals, which affirmed the judgment of the district court on the ground that there was no Fifth Amendment violation because Defendant did not have a liberty interest in being placed on probation and the court’s refusal to place Defendant on probation did not extend the length of Defendant’s sentence. Finding that the trial court violated defendant's Fifth Amendment rights in using the refusal to take the polygraph test as grounds for its judgment, the Supreme Court vacated the district court's order and remanded for further proceedings. View "Idaho v. Van Komen, Jr." on Justia Law

Kentsler Jones appealed his conviction for driving while under the influence of alcohol (DUI), and felony excessive alcohol concentration. On appeal, Jones argued that the district court erred when it excluded evidence regarding the measurement of uncertainty in Jones’s alcohol concentration test result. Specifically, Jones argues that the Idaho Supreme Court’s holding in "Elias-Cruz v. Idaho Dep’t of Transp.," (280 P.3d 703 (2012)), was manifestly wrong and should have been overturned. The Supreme Court declined to overturn "Elias-Cruz" and affirmed Jones' conviction. View "Idaho v. Jones" on Justia Law

On July 12, 2014, around 5:00 A.M., Ben Savage appeared at the Custer County Sheriff’s Office and reported that defendant-respondent Jon Huffaker had pointed a loaded rifle and threatened to kill him. At approximately 6:00 A.M. Sergeant Shawn Kramer located Huffaker walking his dog in a nearby field. Sgt. Kramer did not activate his lights or siren and did not otherwise make contact with Huffaker. Huffaker noticed Sgt. Kramer’s vehicle and approached it. Sgt. Kramer then informed Huffaker of Savage’s allegations against him. At that time, Sgt. Kramer noticed that Huffaker appeared intoxicated. Sgt. Kramer offered to give Huffaker a ride to the Sheriff’s Office so he could give Deputy Levi Maydole his side of the story. Huffaker agreed, and Sgt. Kramer drove Huffaker and his dog to the Sheriff’s Office. During the ride to the Sheriff’s Office, Huffaker rode in the passenger seat of Sgt. Kramer’s law enforcement vehicle while his dog rode in the back seat. In the course of his interaction with Sgt. Kramer, Huffaker was not frisked or handcuffed. He was not physically or verbally coerced by Sgt. Kramer into entering the law enforcement vehicle. He was never told that he was being arrested, detained, or otherwise deprived of his freedom. After a roughly five minute interview, Deputy Maydole informed Huffaker that he was under arrest. Roughly three hours after having been arrested, Huffaker requested and was provided with a “Voluntary Statement” form, on which he wrote down an account of the events from that morning, which contained incriminating statements similar to those he had made during his interview with Deputy Maydole. Prior to trial, the district court suppressed both Huffaker’s interview and his written statement under Miranda. The district court reasoned that Huffaker was “in custody” during the interview because: (1) “Defendant has no way of returning home because he was intoxicated and Kramer had given him a ride to the station”; (2) “Defendant was questioned as the sole suspect by a law enforcement officer”; (3) “[h]e was not told he was free to leave”; and (4) “[a] normal person in Defendant’s circumstances would not have believed they could end the interview and freely leave the police station.” Following entry of the order granting Huffaker’s motion to suppress, the State appealed to the Court of Appeals. The Court of Appeals affirmed the order as to Huffaker’s written statement, but reversed as to his oral statements, concluding that he was not in custody when those statements were made. The Supreme Court vacated the district court's order suppressing both Huffaker's written and oral statements, finding that Huffaker was not in custody when his statements were made, and that the written statement was not drafted in response to interrogation. View "Idaho v. Huffaker" on Justia Law

Defendant-appellant Lance Taylor appealed a district court order denying him credit for time served as a condition of probation. Specifically, the credit he sought was for periods of incarceration during his drug court program. Taylor argued the district court erred: (1) for not giving retroactive effect to the Credit Statutes, Idaho Code 18-309 and 19-2603; and (2) misinterpreting the conditions of his probation, in the event that he was not entitled to credit for his incarceration during the drug court program. After review, the Idaho Supreme Court affirmed the district court's order insofar as it awarded credit for time served for certain periods of Taylor's drug court incarceration. However, the Court reversed the order insofar as it denied credit for certain other periods. The case was remanded for determination of the total number of days to be applied against Taylor's sentence. View "Idaho v. Taylor" on Justia Law

Defendant-appellant Daniel Leary appealed a district court’s order revoking probation and imposing his sentence. He argued the district court erred in calculating his credit for time served. He contended that the 2015 amendments to Idaho Code sections 18-309 and 19-2603 (the "Credit Statutes") should have been given retroactive effect, requiring the district court to give him credit for all time served on previous drug court bench warrants, which were a condition of his probation. The Supreme Court affirmed, finding "an express declaration of retroactive effect is absent from the plain language of the Credit Statutes. The Legislature clearly knows how to expressly declare retroactive effect when drafting a statute, and such a declaration is absent in the Credit Statutes." View "Idaho v. Leary" on Justia Law

Appellant Dale Shackelford was sentenced to death after being convicted of two counts of first-degree murder and other crimes. He appealed and sought post-conviction relief, and his death sentence was set aside. At resentencing, Shackelford was sentenced to two consecutive fixed life sentences. Shackelford petitioned for post-conviction relief based on the resentencing proceeding. He also petitioned again for post-conviction relief based on the original criminal trial. The district court summarily dismissed both petitions and Shackelford appealed each. The appeals were consolidated in this case, and presented the following issues for the Supreme Court's review: (1) whether the district court erred in summarily dismissing Shackelford's amended successive petition; (2) whether the district court erred in summarily dismissing Shakelford's resentencing petition; and (3) whether the district court erred in denying Shackelford's motion for appointment of counsel related to the amended successive petition. Finding no reversible error as to any of Shackelford's issues raised on appeal, the Supreme Court affirmed. View "Shackelford v. Idaho" on Justia Law