Justia Idaho Supreme Court Opinion Summaries

The constitutionality of "Plan L 87," a legislative redistricting plan adopted by the Commission on Redistricting for reapportionment, was challenged and brought before the Supreme Court. Upon review, the Court found that the Plan complied with the strictures of the Fourteenth Amendment's Equal Protection Clause of the federal constitution. However, the Plan did not comply with Article III, section 5 of the Idaho Constitution in that it did not "divide counties only to the extent that [they] must be divided to comply with the Federal Constitution." Furthermore, the Plan did not "avoid dividing counties whenever possible in violation of Idaho Code section 72-1506(5)." The Court did not order the Commission to adopt any one redistricting plan: "The commission certainly has the discretion to reject plans that have been submitted and draw boundaries in another manner that complies with both Constitutions." The Court directed the commission to reconvene and adopt a revised plan. View "Twin Falls County v. Idaho Commission on Redistricting" on Justia Law

In 2003, Defendant Lonnie Forbes pled guilty to attempted lewd conduct with a minor child under sixteen years of age. The district court withheld judgment three months later and placed Defendant on probation for seven years. As a result of his plea, Defendant was required to register as a sex offender. When Defendant committed the crime, Idaho law permitted him to request to withdraw his guilty plea and have the case dismissed. The district court was given discretion to grant Defendant's request so long as Defendant complied with the terms of his probation. Three years later, the law was amended. Three years after that, Defendant's probation was amended to unsupervised probation, with all other terms of probation still in effect. In 2010 when Defendant met the requirements of his withheld judgment, he moved to set aside his guilty plea and for a restoration of his civil rights. The State opposed Defendant's motion to dismiss, but the district court granted Defendant's request. The State appealed, arguing that the change in the law governing Defendant's sentence and probation barred Defendant's ability to have his case dismissed. Upon review, the Supreme Court held that the district court erred by retroactively applying the amended law to Defendant's case. The district court's decision was vacated and the case remanded for further proceedings. View "Idaho v. Forbes " on Justia Law

Defendant-Appellant Matthew Hanson was convicted of aggravated assault. At the sentencing phase, he exercised his Fifth Amendment privilege against self-incrimination and declined to participate in the preparation of the presentence investigation (PSI) report. Defendant later moved the court to order a presentence psychological evaluation. The district court ruled that unless Defendant agreed to participate in the PSI, his motion would be denied on the ground that a defendant may not selectively invoke his Fifth Amendment privilege with respect to different aspects of a single subject. Defendant again declined to participate, and the court denied his motion. Defendant's attorney subsequently requested a competency evaluation, which was also denied. Defendant was sentenced to five years, with three years fixed. He then moved for reconsideration of his sentence, which motion the district court denied. Defendant appealed the district court's denial of his requests for a psychological evaluation and for a competency evaluation. Upon review, the Supreme Court affirmed the district court's denial of Defendant's request for a competency evaluation. However, the Court reversed the district court's denial of Defendant's request for a psychological evaluation because: (1) the record showed Defendant's mental condition would be a significant factor at sentencing; and (2) it incorrectly held that Defendant could not invoke his Fifth Amendment privilege against self-incrimination with regard to the PSI but waive the privilege in order to obtain a psychological evaluation. Accordingly, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Idaho v. Hanson " on Justia Law

Defendant-Appellant Simona Manzanares appealed the judgment entered after she pled guilty under a conditional plea agreement. She pled guilty to recruiting a criminal gang member in exchange for the dismissal of a charge for providing a firearm to a criminal gang member. On appeal, Defendant argued that the "Recruiting Provision" (I.C. 18-8504(1)(a)) was unconstitutionally overbroad on its face and as applied for encroaching on the First Amendment right to free association; that the "Firearm Provision" (I.C. 18-8505) was unconstitutionally overbroad as applied for punishing her "expressive conduct," and unconstitutionally vague on its face and as applied for failing to adequately define "gang member," as well as being unconstitutional under the Second Amendment of the federal and under Article I, Section 11 of the state constitution. Defendant raised additional constitutional claims, and argued that the evidence presented against her at the preliminary hearing was insufficient to support the charges she faced. Upon careful consideration of Defendant's arguments, the Supreme Court concluded that the "Recruiting" and "Firearm" provisions were not unconstitutionally overbroad nor were they unconstitutional as they applied to Defendant. As such, the Court upheld Defendant's conviction pursuant to her conditional plea agreement. View "Idaho v. Manzanares " on Justia Law

In March 2009, the City of Nampa issued a request for proposals regarding obtaining services to prosecute city misdemeanors and infractions. Former Canyon County prosecuting attorney John Bujak desired to contract with Nampa to perform those services. The Canyon County commissioners unanimously adopted a proposal pursuant to permit him to do so. Plaintiff-Appellant Bob Henry filed three public records requests with the county clerk asking for information regarding the contract with Nampa, including "invoices, etc sent to Nampa by county for prosecuting svc." and "an accounting of where those funds are being deposited + how they are being dispursed [sic] to Canyon County." Upon review, the Supreme Court held that the requested records were public records, but that the City could not be required to produce them because it was not the public official who refused to disclose the records. View "Henry v. Taylor" on Justia Law

Defendant-Appellant Daniel Johnson petitioned the district court for an exemption from sex offender registration requirements. The district court determined that the 2009 amendments to the Idaho Sexual Offender Registration Notification and Community Right-to-Know Act (SORA) precluded such exemption and therefore denied his petition. On appeal, Defendant argued that the district court’s application of SORA was unconstitutional. Because Defendant filed his petition in his already-dismissed criminal case, the Supreme Court concluded the district court lacked jurisdiction to consider the matter. The Court therefore vacated the district court’s decision. View "Idaho v. Johnson " on Justia Law

Defendant John Joseph Delling appealed his conviction based on his conditional pleas of guilty to two counts of second-degree murder. Defendant was initially charged with two counts of first-degree murder for the deaths of David Boss and Brad Morse. These counts were later amended to second-degree murder. Shortly after being charged, Defendant's counsel motioned for a mental health evaluation to determine whether Defendant was fit to proceed and able to aid in his own defense. Defendant requested that the Supreme Court reconsider and overrule its decision in "State v. Searcy" (798 P.2d 914 (1990)), to find that Idaho's abolition of the insanity defense was unconstitutional. Defendant also asserted that the district court abused its discretion and imposed excessive sentences. Upon careful review of the applicable legal authority and the arguments presented in Defendant's appellate brief, the Supreme Court concluded Defendant had not provided any argument that showed the precedential cases to be wrongly decided, unwise, or unjust. By looking at each argument individually, none of Defendant's constitutional rights were infringed by the abolition of the insanity defense. Furthermore, the Court also found that the sentence imposed by the district court was reasonable and not an abuse of discretion. View "Idaho v. Delling " on Justia Law

Defendant John Schulz appealed his conviction of felony domestic battery and the attempted strangulation of his fifteen-year-old daughter. Both charges required the state to prove that the daughter was Defendant's "household member" as defined by the applicable statute. The district court granted Defendant's motion to dismiss based on the fact that she did not fall within that definition. Because the Supreme Court found that the definition of "household member" plainly limited the application to "intimate partners" and thus, did not extend to a child living with her father, the Court affirmed. View "Idaho v. Schulz " on Justia Law

Defendant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. In 2007, a jury convicted him for the stabbing death of Cassie Jo Stoddart. Defendant raised multiple issues on appeal, among them, he challenged the sufficiency of the evidence presented at trial. Furthermore, Defendant alleged multiple errors at trial prejudiced him from receiving a fair trial. Upon careful review of the trial court record, the Supreme Court found that the jury was provided with sufficient evidence from which it could reasonably find beyond a reasonable doubt that Defendant was guilty of first-degree murder, and that the trial court did not err in its rulings at trial. Accordingly, the Court affirmed Defendant's convictions and sentences. View "Idaho v. Adamcik " on Justia Law

This appeal arose from Defendant Dean Clay Miller, Jr.'s conviction for burglary, assault with intent to commit robbery, possession of methamphetamine, and being a persistent violator. The Supreme Court reduced this case to two issues: (1) whether a persistent violator enhancement must be alleged in the information to give a court subject matter jurisdiction; and (2) whether Defendant's sentence was excessive and constituted an abuse of discretion. Defendant pled guilty to to the charges against him, but on appeal argued that the district court lacked subject matter jurisdiction because the State did not allege the persistent violator enhancement in the information. He also argued that if the court did have subject matter jurisdiction, the sentence was excessive in light of his mental health condition and other mitigating factors. Upon review, the Supreme Court held that the district court had subject matter jurisdiction to sentence Defendant, and did not abuse its discretion when it sentenced him. View "Idaho v. Miller" on Justia Law