Justia Idaho Supreme Court Opinion Summaries

Defendant-appellant Kristi Hurles pled guilty to grand theft for embezzling from her employer, was sentenced to fourteen years with two years fixed, and was ordered to pay $204,174.61 in restitution. Hurles worked at a restaurant, primarily responsible for maintaining the books, but from time to time, Hurles waited tables and tended the bar. One of her duties as bartender was to sell and pay out on Idaho State Lottery pull-tabs. When the restaurant's owners noticed they were losing money on the lottery pull-tabs, they investigated and learned that Hurles’ payouts on the game were over 12% higher than the maximum possible payout for the game. A lottery investigator concluded that Hurles had inflated the amount of the payouts by approximately $10,000 over the course of a year and pocketed that amount. Hurles appealed her conviction, challenging the restitution order. The Court of Appeals reversed the restitution order in part, affirmed in part, and remanded the case to the district court. The State sought review, which the Supreme Court granted. After review, the Supreme Court affirmed the district court's order requiring restitution in the amount of $10,000 for Hurles’ theft of lottery pull-tab monies. The Court reversed restitution ordered for attorney fees in the amount of $33,857.88 for the third-party lawsuits and a bankruptcy adversary proceeding, and the Court vacated the restitution order for ATM thefts in the amount of $145,440 and the remaining amount of attorney fees incurred by the owners. The case was remanded to the district court for determination of restitution relating to the ATM thefts and the owners’ fees incurred in determining and presenting their embezzlement losses. View "Idaho v. Hurles" on Justia Law

Defendant-respondent Moses Olivas, Jr. was convicted of failing to register as a sex offender. Pursuant to Idaho Code section 18-8311(1), the district court sentenced Olivas to a term of imprisonment of five years. The district court also revoked Olivas's probation on a prior conviction, executed the underlying sentence from that conviction, and retained jurisdiction. The district court ordered the underlying sentence and the five-year sentence for failing to register as a sex offender to run consecutively. Following the period of retained jurisdiction on the prior conviction, the district court suspended Olivas's underlying sentence and reinstated probation. The State appealed the district court's order suspending Olivas's sentence on the prior conviction. The Court of Appeals affirmed the district court's decision. The State petitioned the Supreme Court for review. But finding no reversible error, the Supreme Court affirmed. View "Idaho v. Olivas" on Justia Law

Daniel Ehrlick appealed his conviction for the first-degree murder of a child and the failure to report the death to law enforcement. In the summer of 2009, the Ada County Sheriff's dispatch received an emergency call from Ehrlick reporting that R.M., the eight-year-old son of his live-in girlfriend, Melissa Jenkins, was missing. Ehrlick told dispatchers that R.M. was last seen at 7:00 p.m. on July 24, he had been searching for R.M. for several hours, and everyone was telling him that R.M. was at a birthday party. In the ensuing days, an extensive search was launched to find R.M. The searchers included members of several law enforcement agencies and dozens of citizen volunteers. R.M.'s body was found on August 3, 2009, floating face down in a canal. A large rock was stuffed into a closed cargo pocket of his pants. No evidence was offered as to how, or precisely when, R.M.'s body was placed in the canal. R.M.'s corpse exhibited extensive injuries, including multiple compression injuries to the abdomen and a blow to the head. Both the compression injuries and the head injury were potentially fatal wounds on their own, but would not have resulted in instantaneous death. The State's forensic pathologist testified that R.M.'s death was caused by blunt force trauma to the head and torso due to an assault. Investigators began to suspect Ehrlick and Jenkins were involved in R.M.'s disappearance. Investigators searched the couple's apartment and found a piece of paper taped to a wall which concealed a hole in the drywall. Investigators eventually had the section of drywall scanned in order to create a three dimensional plastic model that was introduced at trial. Investigators suspected that the hole was created when Ehrlick slammed R.M.'s head into the wall. A grand jury returned an indictment charging Ehrlick with first-degree murder and failure to report a death to law enforcement. After trial, a jury unanimously found Ehrlick guilty of both charges. The district court sentenced Ehrlick to two fixed consecutive life sentences. On appeal, Ehrlick argued that the trial court committed multiple errors in the admission of evidence and that the prosecution violated his Fourteenth Amendment right to a fair trial by committing multiple acts of prosecutorial misconduct. Finding no error, the Supreme Court affirmed. View "Idaho v. Ehrlick" on Justia Law

The appeal in this case arose after a jury found Desiree Eliasen guilty of misdemeanor stalking. Following the jury’s verdict, Eliasen moved the magistrate court for a judgment of acquittal, which the magistrate court denied. Eliasen subsequently appealed to district court, arguing the State failed to prove she engaged in "repeated acts" constituting a "course of conduct" under the statute. The district court upheld the jury’s verdict and Eliasen appealed. The Idaho Court of Appeals affirmed, and Eliasen then petitioned the Supreme Court for review. On review, Eliasen argued that there was insufficient evidence to show that she was guilty of misdemeanor stalking because she did not engage in separate instances of stalking. Instead, Eliasen claimed her conduct was one continuous act and therefore insufficient to satisfy the "course of conduct" element under the misdemeanor stalking statute. Finding no reversible error, the Supreme Court affirmed the district court’s decision upholding the jury’s verdict. View "Idaho v. Eliasen" on Justia Law

Elmore County’s decided to terminate employee, plaintiff-appellant Cherri Nix, without providing her a pre-termination hearing pursuant to the Elmore County Personnel Policy (ECPP). Nix filed suit alleging, among other claims, that Elmore County violated the ECPP and breached the covenant of good faith and fair dealing when it terminated her employment without giving her a pre-termination hearing. The district court granted Elmore County’s summary judgment motion on the basis that Nix was an at-will employee subject to termination at any time and for any reason, and that Nix failed to show a contractual relationship with Elmore County that would entitle her to a pre-termination hearing. Nix appealed, but finding no reversible error, the Supreme Court affirmed. View "Nix v. Elmore County" on Justia Law

Defendant-appellant Kenny Struhs pled guilty to vehicular manslaughter, was sentenced to a unified term of fifteen years in prison with ten years fixed, and was ordered to pay restitution to the victim's widow, including an amount compensating her for health insurance premiums she paid for coverage between the time of the accident and the time of Struhs' sentencing. On appeal, Struhs challenged the sentence as excessively harsh and the award of restitution for insurance premiums as unauthorized under Idaho Code section 19-5304. Finding no cause to disturb the trial court's judgment, the Supreme Court affirmed. View "Idaho v. Struhs" on Justia Law

Defendant-appellant Katherine Stanfield was convicted by jury for first degree murder of two year-old W.F. by aggravated battery of a child under twelve years. Defendant raised two issues on appeal: (1) the district court erred in admitting certain expert testimony, claiming that the testimony's admission violated her Sixth Amendment right to confrontation and that the evidence was inadmissible hearsay; and (2) the district court deprived her of her Fourteenth Amendment right to due process and right to a jury trial by failing to properly instruct the jury. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Stanfield" on Justia Law

The Idaho Supreme Court granted a petition for review of a Court of Appeals decision in this case. Irwin Adams appealed a district court’s decision summarily dismissing his post-conviction relief petition, which the Idaho Court of Appeals affirmed. Adams argued on appeal that the district court erroneously: (1) weighed the State’s accident reconstruction expert’s trial testimony against Adams’s accident reconstruction expert’s affidavits; (2) reached its own conclusions as to purported flaws in Adams’s accident reconstruction expert’s conclusions; and (3) wrongfully determined that even if Adams’s accident reconstruction expert’s testimony would have been presented at trial, it would not have changed the outcome of the case. Adams also argued that the district court erred when it dismissed the claim that trial counsel was ineffective for failing to investigate and present evidence that Adams’s vehicle was incapable of going the speeds the State alleged during trial. Finding no reversible error, the Supreme Court affirmed the district court’s decision. View "Adams v. Idaho" on Justia Law

A jury found Azad Haji Abdullah guilty of first-degree murder, first-degree arson, three counts of attempted first-degree murder, and felony injury to a child. The case proceeded to sentencing and the jury found two aggravating circumstances. The jury also found that all the mitigating circumstances when weighed against each aggravating circumstance individually were not sufficiently compelling to make the death penalty unjust. The district court subsequently entered judgments of conviction and sentenced Abdullah to death for first-degree murder and to a total of eighty years imprisonment for the remaining five convictions. Abdullah sought post-conviction relief. After an evidentiary hearing, the district court dismissed Abdullah’s petition for post-conviction relief in its entirety. Abdullah appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed the convictions, the sentences, and the order denying post-conviction relief. View "Georgia v. Abdullah" on Justia Law

In 2011, Corey Thiel was charged with felony domestic battery. Pursuant to a plea agreement, Thiel pled guilty to an amended charge of misdemeanor domestic battery and was placed on supervised probation. Approximately one week after entry of this guilty plea, Thiel was charged with a misdemeanor violation of a no-contact order for an incident that occurred while the battery charge was pending. Thiel pled guilty to violating the no-contact order, and the magistrate court imposed suspended jail time and two years of unsupervised probation, while crediting time served. Under the terms of his probation, Thiel was required to comply with the terms of supervised probation established in the underlying battery case. Less than two months thereafter, on May 2, 2012, the State moved for the court to issue a bench warrant for Thiel’s arrest based on probation violations. At a hearing on the State’s motion, Thiel admitted the violations. The court reinstated Thiel on probation. Approximately four months thereafter, the State moved for a second set of probation violations, alleging that Thiel failed to maintain contact with his assigned probation officer and also failed to provide documentation that he had completed the required domestic violence treatment. At a hearing on the State’s motion, Thiel admitted the violations. The court revoked Thiel’s probation and imposed his original sentence of 356 days, with a credit of 67 days. Fifty-five days before his sentence was to end, the Ada County Sheriff’s Office submitted a letter to the magistrate court recommending that Thiel be granted early release. The magistrate court denied the Sheriff’s request. The issue this case presented for the Supreme Court's review was one of statutory interpretation: Idaho Code section 20-621 authorizes commutation of county jail sentences for good behavior, making county inmates with good records while incarcerated eligible for five (5) days off for each and every month of their sentence. A prisoner’s eligibility, however, was conditioned upon receiving a recommendation from the supervising county sheriff. The primary issue presented here was whether the statute vested the magistrate court with the discretion to reject a recommendation from a sheriff. The Supreme Court affirmed the district court's conclusion that the statute vested no discretion with the magistrate judge. View "Idaho v. Thiel" on Justia Law