Justia Idaho Supreme Court Opinion Summaries

Defendant Todd Carver was convicted of murdering the three-year-old son of his live-in girlfriend. He appealed, arguing that the district court erred in failing to appoint substitute counsel for him, in its instructions to the jury defining the crime, and in calculating his sentence. Finding no reversible error, the Supreme Court affirmed defendant's conviction and sentence. View "Idaho v. Carver" on Justia Law

Defendant-Appellant Jose Brunet appealed a district court's order relinquishing jurisdiction and denying his oral motion requesting leniency pursuant to Rule 35 of the Idaho Criminal Rules. Appellant also argued that the Supreme Court's order denying his motion to augment the appellate record violated his constitutional rights to due process and equal protection, and would deny him effective assistance of counsel on appeal. Upon review of the matter, the Supreme Court affirmed the district court's order and held that appellant failed to show that the denial of his motion to augment the appellate record with additional transcripts violated his constitutional rights. View "Idaho v. Brunet" on Justia Law

The issue before the Supreme Court in this case concerned the district court’s holding that Ashton Urban Renewal Agency (AURA) had standing to challenge a property tax exemption granted to Ashton Memorial, Inc., a corporation with real and personal property located within AURA’s revenue allocation area. Specifically, the issue was whether AURA was a “person aggrieved” under I.C. 63-511, and therefore, could appeal the grant of the exemption to the Idaho Board of Tax Appeals (BTA). The Supreme Concluded that AURA was an "person aggrieved" under the statute, therefore it affirmed the district court's decision. View "Ashton Urban Renewal v. Ashton Memorial" on Justia Law

Defendant-Appellant Joseph Clinton was indicted for felony lewd conduct with a minor under sixteen. Initially he was found incompetent to stand trial, but after reassessment, he was deemed competent. Thereafter he pled guilty, and underwent further assessment prior to receiving sentence. The sentencing court ultimately sentenced defendant to twenty years' incarceration, three years fixed and the remainder indeterminate. Defendant moved for reduction of the sentence, which was denied. The Court of Appeals affirmed defendant's sentence. The issues on appeal to the Supreme Court were: (1) whether the trial court erred in failing to order a mental evaluation sua sponte; and (2) whether the sentencing court abused its discretion in imposing defendant's ultimate sentence. Finding no errors, the Supreme Court affirmed. View "Idaho v. Clinton" on Justia Law

Defendant-Respondent-Appellant Stephen Adams appealed a district court judgment that upheld a magistrate judge's order that dismissed his motions to modify child custody and child support. Defendant's had been held in contempt for failing to make one child support payment. He was unable to purge the contempt by paying all delinquent child support payments for reasons he said were beyond his control. A court can impose a criminal contempt sanction in nonsummary contempt proceedings only if the contemnor has been afforded the federal constitutional rights applicable to criminal contempt proceedings. The magistrate held that it could refuse to hear the Father's motions because he was unable to purge the contempt and could not prove that his inability was due to circumstances beyond his control. The district court held that refusal to hear the Father's motions was a permissible criminal contempt sanction. Idaho Code section 7-610 does not authorize denial of access to the courts as a criminal contempt sanction. Therefore, the district court erred in affirming the magistrate's order on the ground that it was a permissible criminal contempt sanction. The Supreme Court held that the district court erred in affirming the magistrate court's order. In addition, the Supreme Court held that refusal to hear a motion and dismissal of a motion that the contemnor did not purge the contempt violates Article I, Section 18 of the state constitution. The district court was reversed and the case remanded. View "Slane v. Adams" on Justia Law

Defendant-Appellant Timothy Dunlap received the death penalty following his guilty plea to first-degree murder. He appealed the sentence, alleging multiple errors during trial, and that he received ineffective assistance of counsel. Although the Supreme Court found found error in the direct appeal from the sentencing proceedings, it held those errors, individually and cumulatively, were harmless. As to the appeal of the order summarily dismissing defendant's petition for post-conviction relief, the Court held that the district court erred in summarily dismissing defendant's claim of ineffective assistance of counsel regarding the investigation and presentation of mitigating evidence and the rebuttal of the State’s evidence in aggravation and defendant's "Brady/Napue" claim. Therefore, the Court vacated the district court’s judgment granting summary dismissal of defendant's petition for post-conviction relief and remanded the case for further proceedings. View "Idaho v. Dunlap" on Justia Law

Dale Shackelford appealed two consecutive fixed life sentences he received on resentencing for two first-degree murder convictions. He was initially sentenced to death for both murders but the death sentences were subsequently set aside. Shackelford contends that the district court committed error in resentencing him to the consecutive fixed life sentences. Upon review of the district court record, the Supreme Court concluded that the district court did not abuse its discretion nor violate Shackelford's Sixth Amendment right of confrontation. Accordingly, the Court affirmed the judgment of conviction sentencing Shackelford to two consecutive fixed life sentences. View "Idaho v. Shackelford" on Justia Law

Tyler Ray Carter pleaded guilty to aggravated battery on a correctional officer and was sentenced to fifteen years with five years fixed. He appealed the sentence arguing the district court failed to order a separate psychological evaluation prior to sentencing, and also violated his Fifth Amendment privilege against self-incrimination by using pre-trial competency evaluations in making its sentencing determination. Carter did not object to either the use of the competency evaluations or the court?s failure to order a psychological evaluation at trial. The Court of Appeals applied the "manifest disregard" standard to review Carter's claim that the court erred by failing to order a new psychological evaluation, and vacated the sentence. The Supreme Court granted the State's petition for review. The State argued that the fundamental error standard applied to all of Carter's unobjected-to evaulations. Upon review, the Supreme Court disagreed with the State's argument and affirmed the district court's judgment of conviction and sentence. View "Idaho v. Carter" on Justia Law

This appeal stemmed from Native Wholesale Supply Company's (NWS) cigarette sales to Warpath, Inc. NWS is an Indian retailer organized under the tribal laws of the Sac and Fox Nation. It operates on the Seneca reservation in New York. Warpath is an Idaho corporation that operates on the Coeur d'Alene reservation. The State of Idaho brought suit against NWS for acting as a cigarette wholesaler without a permit and for selling cigarettes that are unlawful for sale in Idaho. The district court enjoined NWS from selling wholesale cigarettes in Idaho without a wholesale permit and assessed civil penalties in the amount of $214,200. NWS appealed that decision, arguing the State did not have subject matter jurisdiction or personal jurisdiction. Upon review, the Supreme Court affirmed in part, reversed in part, and remanded to the district court for further proceedings. The Court found that NWS's sales to Warpath were exempt from Idaho taxation, and NWS was not required to obtain a wholesale permit. Furthermore, the State had subject matter over NWS's importation of non-compliant cigarettes into the State of Idaho, and that the State could validly exercise personal jurisdiction over NWS. View "Idaho Tax Commission v. Native Wholesale Supply" on Justia Law

John Doe was in prison when his son was born. The baby's mother was living with another man, and gave the boy the boyfriend's surname. The baby was abused while in her care; the Department of Health and Welfare took the child into custody. The boyfriend was listed as the putative father in a Child Protective Act (CPA) proceeding; after a DNA test, Doe was substituted as the putative father. Prior to the test, Doe had no prior contact with the child. The Department requested termination of Doe's and the biological mother's parental rights. The mother voluntarily consented to the termination. The Department submitted a new petition, requesting for the first time an "Order of Non-Establishment of Parental Rights." The Department averred that Doe was "not the 'parent' of [Son] as [he had] failed to assert any parental rights to [Son] either by statute or by timely establishing some relationship to [Son]." The magistrate judge entered her Findings of Fact, Conclusions of Law and Nonestablishment of Paternity. Doe timely appealed. He raised two issues: (1) whether under Idaho Code he was entitled to an evidentiary hearing prior to the "nonestablishment" of his parental rights; and (2) whether his due process rights were violated. The Supreme Court concluded that Doe did not show he was entitled to an evidentiary hearing prior to the "nonestablishment" of his parental rights, or that his due process rights were violated. View "Doe v. Idaho Department of Health & Welfare" on Justia Law