Justia Idaho Supreme Court Opinion Summaries

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

Defendant Ora Carson was convicted of the murder of his three-month-old son and was sentenced to a fixed life sentence based upon the jury’s finding that he exhibited utter disregard for human life. On appeal, he challenged the trial court’s ruling barring impeachment evidence of the child’s mother, statements made by the prosecuting attorney during closing argument, and the jury instruction defining “utter disregard.” Upon review, the Supreme Court found that Defendant’s trial counsel did not object to the challenged comments: "[b]y the challenged comments, the prosecutor was not expressing a personal opinion regarding the credibility of Mother. Defendant had testified that Mother killed Baby. The prosecutor was merely arguing that Mother’s conduct, as shown by the evidence, was inconsistent with that allegation. The prosecutor and defense counsel are free to argue the evidence and the reasonable inferences that can be drawn from that evidence, even if the evidence argued indicates that a witness is or is not truthful." With regard to the jury instructions given by the trial court, the Supreme Court concluded that Defendant did not present "any logical argument" that the jury would not have understood the meaning of "utter disregard." Accordingly, the Court affirmed the trial court's judgment. View "Idaho v. Carson" on Justia Law

This case involved a custody dispute between Charles Hernandez, the biological father of two minor children, and Janice Ausburn, the children's maternal grandmother. In 2001, the children's mother Kerri left the children with her mother Janice because she was struggling with drug addiction. The children continued to live with Janice and she raised them without physical help from Charles or Kerri. Charles had no physical contact with the children between November 2002 and early 2008. Kerri continued to struggle with personal issues and had nothing to do with the children after turning them over to Janice. Despite acting as the children's primary custodian, Janice never petitioned a court for guardianship. In 2008, Charles and Kerri stipulated to a change in the custody arrangement, whereby Charles would have sole physical custody of the children and Kerri would have visitation each summer. The court entered a modification order based on the stipulation. The court was unaware that the children were actually residing with Janice when it entered the order. Janice was not made aware of either the stipulation or the order. Janice found out about the plan and kept the boys home from school on the day Charles was to take them. Janice then filed a separate action for custody. In the subsequent proceeding, the court considered whether Charles or Janice should be the children's primary custodian. The court ultimately granted Charles sole legal custody and Charles and Janice shared physical custody, with Charles having primary custody and Janice having custody for six weeks during the summers. The court based its decision largely on a court-ordered assessment prepared by a third-party evaluator. Charles appealed the magistrate court's decision to the district court. He did not challenge the magistrate judge's factual findings but, rather, argued the award of limited custodial rights to Janice violated the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Upon review of the trial court record and the applicable legal authority, the Supreme Court affirmed the district court's order. View "Hernandez v. Ausburn " on Justia Law

Cassie Jo Stoddart was murdered in 2006. Defendant Brian Draper, who was sixteen years-old at the time of Stoddart’s murder, and Torey Adamcik, also a juvenile, were arrested and charged with murder and conspiracy to commit murder. Both were tried as adults, and convicted during separate trials. Defendant was sentenced to a term of fixed life imprisonment for the murder charge and a life sentence with thirty years fixed for the conspiracy charge. Defendant raised seven issues on appeal: 1) the jury instructions for both murder and conspiracy relieved the State of proving all elements of the crimes and violated his right to due process of law; 2) his fourth police interview should have been suppressed as his parents were not present at the interview; 3) the jury instructions and the district court’s failure to suppress the interview, even if individually harmless, cumulatively constitute reversible error; 4) the sentences should be vacated because the investigator’s presentence report was biased; 5) Defendant's fixed life sentence for murder violated the Idaho and U.S. Constitutions’ prohibition of cruel and unusual punishment; 6) the district court’s sentences constituted an abuse of discretion; and 7) the district court’s denial of Defendant's motion under Idaho Criminal Rule 35 to modify his sentences constituted an abuse of discretion. Upon review of the trial court's record, the Supreme Court only found error in the jury instruction pertaining to Defendant's conspiracy charge, but affirmed the trial court in all other respects. The Court vacated Defendant's conviction on conspiracy to commit first degree murder and remanded the case for a new trial on that charge. View "Idaho v. Draper " on Justia Law

This case arose from Defendant Diego Morales Peregrina’s conviction on two counts of aggravated battery and two firearm enhancements; one for each battery. Peregrina argued on appeal of his sentence that there was insufficient evidence to support the district court’s "implicit" finding that the crimes arose out of divisible courses of conduct, and that even if there was, the State had the burden to submit the issue of divisibility to the jury and prove it beyond a reasonable doubt. Upon review of the trial court record, the Supreme Court found that no instruction was requested by either Peregrina or the State regarding I.C. 19-2520E, which states that when two crimes "arise out of the same indivisible course of conduct," the defendant "may only be subject to one (1) enhanced penalty." The district court sentenced Peregrina as follows: ten years fixed for the first count of aggravated battery; ten years fixed for the second count of aggravated battery consecutive to the first count; ten years indeterminate enhancing the sentence in the first count; and ten years indeterminate enhancing the sentence in the second count, both consecutive to the previous counts. Peregrina was also sentenced to five years fixed for his conviction for unlawful possession of a firearm, to run concurrent with the other sentences, with credit for two hundred days served. The Supreme Court found that the State's failure to submit the issue of divisibility to the jury and to prove it beyond a reasonable doubt. The Court remanded the case back to the district court for further proceedings. View "Idaho v. Peregrina " on Justia Law

Defendant Christopher Flegel was indicted by a grand jury for lewd conduct with a child under sixteen in violation of Idaho Code section 18-1508. Defendant pled not guilty and was tried by a jury. The district court instructed the jury regarding the crime of Lewd Conduct and, as an included offense, the crime of sexual abuse of a child under sixteen years of age. The jury found Defendant not guilty of Lewd Conduct, but could not reach a verdict on the Sexual Abuse charge. Without resubmitting the matter to a grand jury, the State filed an amended indictment charging Defendant with Sexual Abuse. Defendant was tried by a jury on that charge and found guilty, to which he appealed. The appeal was initially heard by the Idaho Court of Appeals. It held that the indictment was properly amended because evidence admitted during Defendant's first trial supported the included offense of Sexual Abuse; and that the district court erred in failing to tailor the jury instruction on Sexual Abuse to eliminate the risk that the jury in the second trial would find Defendant guilty of conduct for which he was acquitted in the first trial. Because it concluded that such error was not harmless, the Court of Appeals vacated the judgment and remanded the case for a new trial. Upon review, the Supreme Court held that because the Sexual Abuse crime had not been submitted to the grand jury and was not an included offense of the crime of lewd conduct charged in the original indictment, the district court did not have subject matter jurisdiction. The Court therefore vacated the judgment and remanded the case with instructions to dismiss without prejudice. View "Idaho v. Flegel " on Justia Law