Justia Idaho Supreme Court Opinion Summaries

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

A grand jury indicted Michael Koch on four counts of lewd conduct with a minor under sixteen with “C.C.” named as the complaining witness in all counts. Count I alleged the crime was committed “by manual to genital and/or oral to genital contact” between January and May 2011. Counts II, III, and IV all alleged genital to genital contact in April 2011. On appeal, Koch argued the district court made multiple errors in the admission of evidence that warrant reversal of his judgment of conviction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Koch" on Justia Law

These are two cases out of Bannock County that were consolidated on appeal. In the first case, defendant was convicted of attempting to elude a peace officer, a felony, and of malicious injury to property and assault, both misdemeanors. In the second case, defendant was convicted of grand theft, a felony. For each felony, he was sentenced to eighteen years in prison, with eight years fixed and ten years indeterminate, and the sentences were ordered to be served consecutively. On appeal of both cases, defendant challenged the evidence presented against him, and alleged procedural errors by the trial courts to reverse the sentences he received. Upon review, the Supreme Court found no reversible errors, and affirmed defendant's convictions and sentences. View "Idaho v. Skunkcap" on Justia Law

What began as a disagreement between neighbors, ended with defendant-appellant Nathan Herren being charged with misdemeanor malicious injury to property - a charge to which he pled guilty. The magistrate court entered a withheld judgment and a no contact order in July 2008, which stated "[i]t is hereby ordered that [Herren] shall not contact (including: in person or through another person, or in writing or e-mail, or by telephone, pager, or facsimile) or attempt to contact, harass, follow, communicate with, or knowingly remain within 100 feet of: Kip McDermott.” In January 2009, despite knowing that McDermott would likely be present, Herren attended a homeowner’s association meeting at a local elementary school. Herren arrived prior to McDermott and sat in the middle of the room. Once McDermott arrived, Herren moved from his seat in the middle of the room to the back of the room, but did not leave the meeting. McDermott contacted law enforcement because of Herren’s continued presence at the meeting. Herren was arrested and charged with the crime of violation of a no contact order. The arresting officer testified that the room was seventy-five feet long. Herren testified that he decided to stay at the meeting because he believed the room was more than 100 feet long. However, Herren admitted that he returned to the library at a later date, measured the room, and found the room was eighty-one feet long on the diagonal. The magistrate court found Herren guilty of violating the no contact order because he knowingly remained within 100 feet of McDermott. The State filed a motion alleging that Herren had violated the terms of probation in the malicious injury to property case. Herren admitted to violating his probation. As a consequence, the magistrate court revoked Herren’s withheld judgment and entered a judgment of conviction for misdemeanor malicious injury to property. Herren appealed both his judgment of conviction for violating the no contact order and the revocation of his withheld judgment for the malicious injury to property charge. The district court rejected Herren’s argument and determined that there was substantial evidence to support the magistrate court’s determination that Herren was guilty of violating the terms of the no contact order by willfully remaining within 100 feet of McDermott. The district court affirmed Herren’s judgment of conviction and the finding that he had violated the terms of his probation. Herren appealed and the Court of Appeals, in a split decision, reversed. The State appealed, and after its review, the Supreme Court affirmed in part, and reversed in part. The Supreme Court found there was not substantial and competent evidence to support a conviction under the no-contact order. However, substantial and competent evidence was in the record to support the revocation of Herren's probation. View "Idaho v. Herren" on Justia Law

The State charged Kyle Richardson with three counts of delivery of a controlled substance. After a preliminary hearing in which a confidential informant testified for the State, the State filed a motion requesting that the district court allow the State to admit into evidence at trial a transcript of the confidential informant’s preliminary hearing testimony. The State sought admission of the confidential informant’s testimony because the confidential informant had died and thus was unavailable as a witness for trial. The district court issued an opinion and order denying the State’s motion. The State filed a motion for a permissive appeal of the district court’s order. Upon review, the Supreme Court concluded that Richardson's rights under the Confrontation Clause were not violated by the admission of the informant's preliminary hearing testimony. Furthermore, the Court concluded that Idaho law governing the admission of preliminary hearing transcripts permitted the admission of the testimony at trial. Accordingly, the Court reversed the district court and remanded the case for further proceedings. View "Idaho v. Richardson" on Justia Law