Justia Idaho Supreme Court Opinion Summaries

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

The City of Hayden provided sewer service to the residents living in the City and to some persons living outside the City. To do so, the City entered into a joint powers agreement with the Hayden Area Regional Sewer Board, which operated a regional wastewater treatment plant serving the City and two other local entities. The City charged each customer it serves a bi-monthly fee, which covered a proportionate share of the operation and maintenance of the City's sewer collection system and of the operation and maintenance costs associated with the regional wastewater treatment facility. In addition to the bi-monthly fee, the City charged a one-time "sewer capitalization fee" for each new structure, whether residential or commercial, and for any addition to an existing commercial structure that would result in an increase in the volume of sewage generated. The capitalization fee was charged when a building permit is issued. In March 2006, the City contracted with an engineering company to update the City's sewer master plan. The engineering company submitted a capital improvement plan in which it recommended forty projects that would cost about $20 million in order to replace existing infrastructure and to construct new infrastructure so that the sewer system would reach the entire area of city impact and accommodate anticipated future population growth. In order to finance the project, the engineering company recommended that the part of the capitalization fee retained by the City be increased from $735 for one equivalent residence ("ER") to $2,280 for one ER. In 2010, the North Idaho Building Contractors Association filed suit to have the fee declared unlawful because it was an impermissible tax rather than a fee for services. The district court held that it was lawful and entered a judgment dismissing the complaint. The City requested an award of attorney fees, which the court denied. The Contractors Association appealed the dismissal of its complaint, and the City cross-appealed the denial of an award of attorney fees. Because there was nothing in the record showing that as of June 7, 2007, the sum of $2,280 was the actual cost of providing sewer service to a customer connecting to the City sewer system and there was no showing that the amount of the fee was based upon any such calculation, the fee was not authorized by Idaho Code section 63-1311(1). The Supreme Court concluded the district court erred in holding that it was. View "No. Idaho Bldg Contractors Assoc. v. City of Hayden" on Justia Law

William Wolfe appealed the Idaho County district court’s decisions denying: (1) his motion for a hearing on his motion for reconsideration of his I.C.R. 35 motion to correct an illegal sentence; and (2) his successive Rule 35 motion to correct an illegal sentence. Specifically, Wolfe argued the district court denied his motions based on two erroneous conclusions: that the subject matter jurisdiction issue had been previously adjudicated and that Wolfe could not file a successive Rule 35 motion. Wolfe argued that if the district court had properly considered the merits of his motions, the district court would have found it lacked subject matter jurisdiction over Wolfe’s original criminal proceedings. Accordingly, Wolfe petitioned the Supreme Court to vacate his judgment of conviction and sentence, or alternatively, to remand the case for an evidentiary hearing. After careful consideration of the district court record, the Supreme Court found no reversible errors, and affirmed the district court’s decisions denying Wolfe’s motion for a hearing and his successive Rule 35 motion. View "Idaho v. Wolfe" on Justia Law

The issue this appeal presented for the Supreme Court's review arose from a district court’s denial of Dameniel Owens’s motion for credit for time served. The district court specified that Owens would only receive credit for his prejudgment time served in a county jail on one of his eight counts of issuing a check without funds. Owens argued that Idaho Code section 18-309 plainly and unambiguously required the district court to credit his prejudgment time served to each of his eight counts. Owens further argued that the Supreme Court should have overruled "Idaho v. Hoch," (630 P.2d 143 (1981)), because in that case the Court improperly went beyond the statute’s plain meaning to hold that the legislature intended a defendant could not receive credit for each separate crime. The Supreme Court indeed overruled "Hoch," vacated the district court’s order denying Owens’s motion for credit for time served, and remanded the case for further proceedings. View "Idaho v. Owens" on Justia Law

Defendant David Knutsen appealed a jury verdict finding him guilty of four counts of sexual abuse of a vulnerable adult. Defendant argued on appeal that the term of the grand jury that indicted him had already expired, that the statute defining the crimes was unconstitutional, that there was insufficient evidence to support the jury’s verdict, and that his conviction should be for only one count because his conduct constituted one continuous act. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Knutsen" on Justia Law

A jury found defendant Joseph Thomas, Jr. guilty of first degree murder for the strangulation death of his ex-wife, Beth Irby Thomas in 2011. A friend of Defendant testified that at about 12:30 a.m. the following day, Defendant came to the friend’s home and stated that he had strangled the decedent. After Defendant left, the friend called 911. The first police officer to arrive at the decedent’s home found her with a leather belt cinched tightly around her neck. The belt was Defendant’s, and he was standing outside her house when the police arrived. After review of defendant's arguments on appeal, the Supreme Court concluded that because the district court erroneously excluded evidence that could have corroborated the defendant’s version of what had occurred and the State did not show that such error was harmless, the Court vacated the jury verdict and the judgment and remanded this case for further proceedings. View "Idaho v. Thomas" on Justia Law

In 2012, Idaho State Police stopped defendant-respondent Derek Arrotta for a traffic violation. At the end of the stop, defendant was issued a citation for misdemeanor driving while under the influence of alcohol. Defendant filed a motion to suppress “based on violations of the defendant’s right to be free from unreasonable search and seizure, right to remain silent, right to counsel, and related constitutional protections under the State of Idaho Constitution and the United States Constitution,” but the motion did not identify what evidence he wanted to suppress or how his rights were allegedly violated. The parties agreed to postpone the matter until the United States Supreme Court decided "Missouri v. McNeely." After the Supreme Court issued its opinion in McNeely, the magistrate court held an evidentiary hearing on the motion to suppress. The trooper testified to the events and stated that he did not recall telling Defendant that he did not have a right to refuse the blood test. However, he also testified that he told Defendant that if he refused the breath test, the trooper would get a blood draw. Defendant testified that he refused the breath test, but not the blood test. He testified that at the hospital he asked if he could refuse the blood test, “but they pretty much said no.” When asked if the trooper told Defendant he could not refuse the blood draw, Defendant answered, “Yeah, something to that extent.” The magistrate court did not resolve the factual dispute regarding whether Defendant was told that he could not refuse the blood draw. Rather, it held that statutory implied consent was insufficient by itself to constitute consent to a search in the form of a blood draw; that express consent was required. Based upon that holding, the court granted Defendant’s motion and issued an order suppressing the blood test results. The State appealed to the district court. The district court affirmed the suppression order, holding that statutory implied consent to a blood draw is revocable. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Arrotta" on Justia Law