Justia Idaho Supreme Court Opinion Summaries

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

In 2012, a Post Falls police officer was searching for a gray truck with stolen Washington license plates. He located and began to follow the truck, and he confirmed that the license plate on it was stolen. The truck stopped in a parking lot in Post Falls, and the officer told the driver, later identified as defendant Dennis Halseth, to stay in the vehicle. Defendant drove away, with the officer in pursuit. Defendant was later stopped and arrested in Washington by a Washington state trooper. The trooper asked Defendant to complete voluntary field sobriety tests, and Defendant refused. The trooper then transported Defendant to a hospital in Spokane, Washington, to have his blood drawn for evidentiary testing. Despite defendant's protests, the hospital technician drew blood samples from each of defendant’s arms. No search warrant was obtained prior to the blood draws. The State of Idaho charged defendant with several crimes including driving while under the influence of alcohol, which would be a felony because of his prior convictions. Defendant moved to suppress the evidence on the ground that he did not consent to the warrantless search. He did not contend that the trooper lacked probable cause to believe that he had been driving under the influence of alcohol. In light of the decision of the United States Supreme Court in "McNeely," the State did not argue that the natural dissipation of alcohol in the bloodstream was an exigent circumstance justifying a warrantless search, nor did it argue that there were any other exigent circumstances justifying the search. The State argued that both Washington and Idaho had statutes providing that persons who drove on public roads impliedly consented to a test for alcohol concentration in their blood; and that Idaho case law held that there was no legal right to withdraw that implied consent; and that the implied consent included a blood draw. The district court granted the motion to suppress, and the State appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Halseth" on Justia Law

Defendant Juan Luis Sanchez-Castro was indicted, tried, and convicted of one count of conspiracy to traffic in 400 grams or more of methamphetamine and one count of trafficking in 400 grams or more of methamphetamine. For each crime, he was sentenced to fifteen years in the custody of the Idaho Board of Correction, with the first ten years fixed and the remaining five years indeterminate, and a fine of $25,000. The district court ordered that the prison sentence on the second charge run concurrently with the prison sentence on the first charge. Defendant appealed, arguing that the conspiracy charge and the trafficking charge were, under Idaho law, the same charge. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Sanchez-Castro" on Justia Law

The Kootenai County Prosecutor filed a two-count information against Jesse Elias alleging that he committed forcible sexual penetration by use of a foreign object (to a minor child), and burglary. The matter proceeded to trial and the jury found Elias guilty of both counts. Elias was sentenced to fifty years imprisonment, with ten years fixed for the first charge; for burglary, Elias received a concurrent ten year fixed sentence. The district court retained jurisdiction for one year. At the completion of the retained jurisdiction, the district court suspended the sentences and placed Elias on probation for fourteen years. Elias appealed, and the Court of Appeals found insufficient evidence of use of force to sustain Elias’ conviction for forcible penetration by a foreign object. The issue presented by this appeal was whether the State produced sufficient evidence at trial to support the jury’s finding that Elias was guilty of forcible sexual penetration by use of a foreign object. The outcome of this appeal turned upon what the Legislature intended when it used the word “force” in Idaho Code section 18-6608. Upon review, the Court reversed the judgment of conviction for forcible penetration by a foreign object and remanded for further proceedings to modify the length of Elias’ probation. View "Idaho v. Elias" on Justia Law

Gary Schall was arrested for driving under the influence of alcohol. He had two prior convictions for driving under the influence within the previous ten years, one of which stemmed from a 2004 arrest in Wyoming. As a result of his prior convictions, the State enhanced his DUI charge to a felony. At the preliminary hearing, the magistrate found that there was probable cause to bind the case over to district court. Schall filed a motion to dismiss in the district court, arguing that the State had the burden at the preliminary hearing to provide probable cause to believe his Wyoming DUI conviction was for a "substantially conforming foreign criminal violation," that the State failed to meet that burden, and that the Wyoming conviction was not in fact a substantially conforming violation. The district court denied Schall's motion, finding that the State met its burden at the preliminary hearing and that the Wyoming statute substantially conformed to Idaho's DUI statute. Schall appealed and the Court of Appeals reversed. The State appealed, and now the Supreme Court reversed, concluding the district court correctly denied Schall's motion to dismiss. View "Idaho v. Schall" on Justia Law

Jonathan Ellington was convicted of second-degree murder and two counts of aggravated battery. He moved for a new trial, arguing that he discovered new material evidence that could not have been produced at trial through reasonable diligence. The evidence consisted of statements in a textbook authored by the State's accident reconstruction expert that, according to Ellington, directly conflicted with the expert's trial testimony. The district court denied Ellington's motion. Upon review of Ellington's arguments on appeal, the Idaho Supreme Court concluded the district court did not abuse its discretion in denying Ellington's motion for a new trial. View "Idaho v. Ellington" on Justia Law

The State appealed a district court's grant of Micah Wulff's motion to suppress evidence obtained in a warrantless blood draw. The draw took place after Wulff was in custody for driving under the influence. The district court held that the United States Supreme Court's holding in "Missouri v. McNeely," suggested that warrantless blood draws are not always permitted under Idaho's implied consent statute. The State argued that McNeely was limited to the exigent circumstances exception to the warrant requirement and Idaho's implied consent statute is a valid exception to the warrant requirement. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Wulff" on Justia Law

Defendant Charlynda Goggin was convicted for conspiracy to manufacture, deliver or possess with intent to deliver a controlled substance; conspiracy to deliver or possess with intent to deliver drug paraphernalia; delivery of a controlled substance; and delivery of drug paraphernalia. After the jury returned a guilty verdict, Goggin filed a motion to acquit and a motion for a new trial. The district court denied the motion to acquit but granted the motion for a new trial on the conspiracy charges, holding that the jury should have been instructed that mistake of law is a defense to conspiracy. Upon review, the Supreme Court affirmed the district court’s decision to deny Goggin’s motion to acquit and to deny Goggin’s motion for a new trial on the delivery charges. The Court reversed the district court’s decision to grant Goggin a new trial on the conspiracy charges. View "Idaho v. Goggin" on Justia Law