Justia Idaho Supreme Court Opinion Summaries

This case was the sixth appeal considered by the Idaho Supreme Court following petitioner-appellant Timothy Dunlap’s guilty plea to first-degree murder. The district court summarily dismissed Dunlap’s successive petition for post-conviction relief. Dunlap raised several substantive claims for post-conviction relief. For each claim, he advanced a corresponding claim of ineffective assistance of appellate counsel. After review and finding no reversible error, the Supreme Court affirmed the district court’s summary dismissal of Dunlap’s successive petition for post-conviction relief. View "Dunlap v. Idaho" on Justia Law

This appeal from arose from proposed repairs and improvements to the City of Challis’ water distribution system. In 2013, the City initiated a judicial confirmation proceeding seeking approval to incur $3.2 million in debt without a public vote. The Consent of the Governed Caucus challenged the constitutionality of the City’s request based upon Article VIII, section 3 of the Idaho Constitution. The district court granted the City’s request and the Caucus appealed. Finding that the district court erred by failing to apply the legal standard for what constitutes a "necessary" expense under the Idaho Constitution, the Supreme Court reversed the district court's decision and remanded for further proceedings. View "City of Challis v. Consent of the Governed Caucus" on Justia Law

The Coeur d’Alene Tribe (Tribe) petitioned the Idaho Supreme Court for a Writ of Mandamus to compel the Secretary of State to certify Senate Bill 1011 (S.B. 1011) as law. On March 30, 2015, both the Senate and the House of Representatives passed S.B. 1011 with supermajorities. S.B. 1011 had one purpose: to repeal Idaho Code section 54-2512A, a law which allowed wagering on “historical” horse races. The Tribe alleged that the Governor did not return his veto for S.B. 1011 within the five-day deadline under the Idaho Constitution. The Tribe argued that because the veto was untimely, the bill automatically became law and the Secretary of State had a non-discretionary duty to certify it as law. The Supreme Court agreed and granted the Writ. View "Coeur d'Alene Tribe v. Denney" on Justia Law

The State appealed the magistrate court's dismissal of the State's motion for contempt brought against Luis Juarez for failing to make payments ordered in a juvenile proceeding. In 2002, Juarez admitted to committing an offense that would have been a misdemeanor if he had been an adult. Much time passed and the court entered several orders directing Juarez to pay fees and restitution in varying sums. Eventually, on October 6, 2005, the magistrate court entered its Amended Financial Judgment and Order directing Juarez to pay restitution. Juarez failed to pay, and would fail to appear twice, resulting in bench warrants for his arrest being issued both times. By the second time Juarez came before the magistrate judge, he was over 26-years old, and outside of the juvenile court's jurisdiction. The court reasoned that now that Juarez had been brought in for an adult felony charge, it could no longer hear the contempt proceedings for failing to pay restitution. The district court reasoned that contempt was not available to compel payment of a restitution obligation arising from a proceeding under the JCA because the magistrate court's jurisdiction was conveyed by operation of Idaho Code section 20-505 and withdrawn by operation of Idaho Code section 20-507. The Supreme Court reversed the district court, concluding: (1) the magistrate court had jurisdiction over a charge of misdemeanor contempt under Idaho Code section 18-1801 (and if the offender was under eighteen years of age at the time of the criminal contempt, and the juvenile court exercises its discretion to treat the offense under the JCA, then Idaho Code section 20-507 would operate to terminate the juvenile court's jurisdiction as the proceedings would arise out of the JCA); (2) based on the State's own affidavit, the alleged crime was committed more than four years before these proceedings were commenced; (3) although this action was processed as a criminal case, no complaint was ever filed; (4) despite the lack of a complaint and without a finding of probable cause, the magistrate court issued warrants which resulted in Juarez's arrest; (5) the court's written "Statement of Rights and Explanation of Procedures for Contempt of Court" erroneously advised Juarez that the State bore the burden of proving the contempt "by a preponderance of the evidence;" (6) the court erroneously advised Juarez of the potential penalties upon conviction for misdemeanor contempt (18-1801 did not prescribe the penalty for misdemeanor contempt); (7) the magistrate court did not appear to recognize that Juarez had a right to a jury trial for misdemeanor contempt; and (8) Juarez appeared before the court without counsel, and Juarez discussed his case with the prosecutor without a knowing and voluntary waiver of the right to the assistance of counsel. The Supreme Court reversed the district court's decision affirming the magistrate court's order dismissing the State's motions for contempt. The case was remanded for further proceedings. View "Idaho v. Juarez" on Justia Law

Jesse Riendeau was arrested for driving while under the influence of alcohol by a Coeur d’Alene police officer. The officer transported him to the jail, where the officer asked that Riendeau submit to a breath test for alcohol concentration. He did, and the two tests showed an alcohol concentration in excess of the statutory limit. Riendeau was charged with driving while under the influence of alcohol. Riendeau filed a motion to suppress the results of the breath test on the ground that the breath test constituted a search and that his consent to that search was obtained unconstitutionally by the threat of a civil penalty of $250 and a one-year suspension of his driving privileges and by the false statement that he was required by law to submit to the breath test. On May 6, 2013, he filed a motion in limine seeking to exclude from evidence the result of the breath test because the State Police’s change of the word “must” to “should” in its standard operating procedures resulted in there being no standards to ensure the reliability of the test results. After an evidentiary hearing, briefing, and argument, the magistrate court denied both motions. Riendeau then pled guilty to driving under the influence of alcohol pursuant to a conditional plea agreement which provided that he would enter a conditional plea of guilty, that he could appeal the orders denying his motions, and that if he prevailed on appeal he could withdraw his guilty plea. The court accepted the plea agreement and sentenced Riendeau. He then appealed to the district court, and it affirmed the magistrate court. He then appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Riendeau" on Justia Law

Andrew Garcia admitted to committing an offense that would have been a misdemeanor if he were an adult. He was ordered to pay court costs of $20.00. After Garcia admitted to committing another offense and a probation violation, he was ordered to pay court costs, probation fees, and community service fees. On May 10, 2010, Garcia admitted to committing another offense and was once again ordered to pay court costs and probation supervision fees. After he failed to make those payments, the State filed a motion for contempt. The magistrate court dismissed the motion, concluding that it did not have jurisdiction because Garcia was then over twenty-one and juvenile court jurisdiction was terminated by operation of Idaho Code section 20-507. The State appealed and the district court affirmed the magistrate court’s order. The State appealed the decision of the district court. After review, the Supreme Court concluded the trial court possessed the inherent power to adjudicate Garcia's alleged contempt, and incorrectly dismissed the State's motion for contempt for lack of jurisdiction. The district court was reversed and the case remanded for further proceedings. View "Idaho v. Garcia" on Justia Law

Defendant-appellant Shannon McKean (a/k/ "McKeam) appealed after she was convicted by jury on five counts of possession of a controlled substance with intent to deliver and two counts of aiding and abetting the delivery of a controlled substance. McKean argued the district court erred by determining that a substance known as "AM-2201" was a controlled substance under the version of Idaho Code section 37-2705(d)(30) then in effect. Furthermore, McKean argued that the district court erred by excluding laboratory reports relating to the products McKean was charged with possessing and delivering. These reports stated that test samples of the products did not show the presence of illegal synthetic cannabinoids. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. McKean" on Justia Law

This appeal from Custer County relates to proposed repairs and improvements to the City of Challis’ (the City) water distribution system. In 2013, the City initiated a judicial confirmation proceeding seeking approval to incur $3.2 million in debt without a public vote. The Consent of the Governed Caucus (the Caucus) challenged the constitutionality of the City’s request based upon Article VIII, section 3 of the Idaho Constitution. The district court granted the City’s request and the Caucus appealed. Upon review, the Supreme Court reversed. The Court found that the district court erred in failing to apply the legal standard for determining what constituted a "necessary" expense under the Idaho Constitution (Article III), articulated in recent case law. As such, the Supreme Court concluded the district court erred in finding the project "necessary" under the tests articulated by case law. The Court therefore reversed the district court's judgment in Challis' favor, and remanded the case for further proceedings. View "City of Challis v. Consent of the Governed Caucus" on Justia Law

Defendant-appellant Felicity Haynes was arrested by a state trooper for driving while under the influence of alcohol. Defendant appealed a district court order affirming the orders of the magistrate court, arguing the magistrate court erred in: (1) granting a continuance to the State due to the unavailability of a witness; (2) refusing to appoint a separate judge to hear a request for funds for the defense; (3) denying a motion in limine to exclude the results of a breath test on the ground that procedures for administering the test had not been properly adopted by the Idaho State Police; and (4) finding defendant’s consent to the breath test was invalid because it was obtained by the threat of a monetary penalty and loss of her driver’s license for one year. Finding no reversible error, the Supreme Court affirmed the order. View "Idaho v. Haynes" on Justia Law

Defendant Bryann Lemmons was convicted by jury on two counts of trafficking in methamphetamine by delivering methamphetamine and two counts of trafficking in methamphetamine by conspiring to deliver methamphetamine. The charges arose from two instances in which Defendant, with the assistance of a co-conspirator, agreed to, and then delivered methamphetamine to a confidential informant. The actual weight of the methamphetamine delivered was less than 28 grams. However, the confidential informant testified that in each transaction Defendant represented that she was delivering an ounce of methamphetamine. In addition, the confidential informant testified that Defendant, through the co-conspirator, had agreed to sell one and one-half ounces of methamphetamine, but when the transaction occurred he was told that Defendant could only obtain one ounce and would provide the half ounce later. Before Defendant was sentenced, she moved for a judgment of acquittal on the counts relating to trafficking on the ground that there was insufficient evidence admitted during the trial to show that one ounce equaled 28 grams or more. After briefing and argument, the district court granted a new trial with respect to the jury questions of whether the person who sold or delivered the methamphetamine represented that it weighed 28 grams or more and with respect to the two charges of trafficking by conspiracy to deliver methamphetamine. The State then filed a notice of appeal. The following day, Defendant filed a motion for reconsideration, asking for judgments of acquittal rather than a new trial. After briefing and argument, the district court granted judgments of acquittal as to the charges of trafficking by conspiring to deliver methamphetamine and as to the issue of whether the person who sold or delivered the methamphetamine had represented that it weighed 28 grams or more. Defendant then filed a notice of cross-appeal. The Supreme Court, after review, concluded the district court's order granting the motion for reconsideration was void. Furthermore, the Court found that testimony that Defendant represented that the weight of the drug was one ounce was, as a matter of law, testimony that Defendant represented the weight was more than 28 grams (an ounce equals slightly more than 28 grams). "A witness need not testify in the wording of a criminal statute in order to prove a violation of that statute as long as the witness’s testimony shows a violation of the statute. It is the substance of the testimony, not the particular words used, that is material." The Court found the evidence presented at trial sufficient to support conviction on trafficking. The Court reversed the grant of a new trial and remanded this case for sentencing on all trafficking charges. View "Idaho v. Lemmons" on Justia Law