Justia Idaho Supreme Court Opinion Summaries

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

Defendant Matthew Taylor 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; and delivery of a controlled substance. After the jury returned a guilty verdict, Taylor filed a motion to acquit and a motion for a new trial. The district court denied the motion to acquit, and for a new trial on the delivery charge, 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 Taylor’s motion to acquit and to deny Taylor’s motion for a new trial on the delivery charge, and reversed the district court’s decision to grant Taylor a new trial on the conspiracy charges. View "Idaho v. Taylor" on Justia Law

Defendant-appellant Krystal Easley appealed the revocation of her probation, and the Supreme Court's partial denial of her request to augment the record with various transcripts (to be created at the public's expense). Defendant was charged with possession of a controlled substance. She entered an "Alford" plea to possession of a controlled substance in late 2005. The district court imposed a sentence of four years with two years fixed but suspended the sentence and placed Easley on probation. In early 2007, the State alleged that Easley violated various terms of her probation. Later that year, Easley admitted to violating the terms of her probation for failure to stay in contact with her probation officer, absconding, failing to maintain employment, and failing to pay the costs of her supervision. The district court revoked Easley’s probation and reinstated her original probation. In 2010, the State moved to revoke probation, alleging that Easley again violated various terms of her probation. The State also charged Easley by Information with possession of a controlled substance. Easley pled guilty to possession of a controlled substance in the second case. She also admitted to violating the terms of her probation by changing her residence without permission, consuming methamphetamine, possessing methamphetamine, having contact with a prohibited person, and failing the pay the costs of her supervision. The district court imposed a concurrent unified sentence of seven years with three years fixed on the new charge, but the court retained jurisdiction. On review of Easley’s period of retained jurisdiction, the district court suspended Easley’s sentences in both cases and placed her on probation. In 2011, the State filed a motion to revoke probation in both cases. Easley admitted to violating the terms of her probation for failing to obtain a substance use evaluation, failing to provide a drug test, changing her residence without permission, failing to make herself available for supervision, failing to report to her probation officer, and failing to complete community service. Easley was in contact with the Twin Falls mental health court coordinator; the mental health court coordinator determined that she would be a good candidate for mental health court. The prosecutor did not agree with the recommendation. The district court ruled that it did not possess the authority to place Easley into the mental health court program. The district court then revoked probation in both cases and executed the underlying sentences. However, the district court sua sponte reduced Easley’s sentence in the second case to a unified sentence of seven years with two years and six months fixed. Easley filed a motion to augment the record with various transcripts. The State objected. The Supreme Court entered an order granting Easley’s request for two transcripts, but it denied her request for transcripts of the admit/deny hearing, a October, 200, disposition hearing, and a February 2011 rider review hearing. "The flaw in this process [was] that the district court did not consider the alternative of mental health court in sentencing. It precluded itself from considering what may or may not have been a preferred alternative." The Supreme Court remanded the case for the district court to consider all alternatives available to the sentencing court. View "Idaho v. Easley" on Justia Law

A woman sleeping in the bedroom of her apartment in Nampa, Canyon County, Idaho, awakened to see an unknown male standing over her with a knife in his hand. He was wearing a mask that covered his face and exposed his eyes. He put a hand over her mouth and held a knife against her throat, and stated that she was going to cooperate. He initially attempted several sexual acts, but was unable to obtain an erection. He then had her lie on her back at the bottom of the bed, where he raped her. He wore a condom and used his cell phone to take photos of her during the rape. Before leaving, he took her sheets and a pillow case. He also had her remove the battery from her cell phone, and he placed it under clothing in her panty drawer. She ran to a neighbor’s house, where she called 911. Defendant was immediately the focus of law enforcement - Nampa police had been investigating him for an assault and battery in Nampa that took place a year earlier. Defendant was ultimately convicted for rape, first degree kidnapping, and burglary. Defendant challenged the admission of evidence first discovered in the warrantless search of his cell phone and of evidence regarding his rape fantasies and his possession of pornography depicting rape. Upon review of this matter, the Supreme Court held that the information obtained during the warrantless search of defendant's cell phone was admissible under the independent source doctrine and that the district court did not abuse its discretion in admitting evidence regarding the Defendant’s rape fantasies and his pornography depicting rape. View "Idaho v. Russo" on Justia Law