Justia Idaho Supreme Court Opinion Summaries

In 2004, a jury found Petitioner Erick Hall guilty of first-degree murder, kidnapping and rape. Petitioner was sentenced to death. Petitioner appealed his conviction, and was appointed a public defender. In 2005, Petitioner petitioned the district court for post conviction relief. In that proceeding, the district court limited contact between Petitioner's counsel and the jurors that convicted him. Petitioner moved for reconsideration. In 2006, Petitioner moved to depose his trial attorneys and their investigator. The court allowed the deposition of trial counsel, but denied leave to depose the investigator. Petitioner's petition for post conviction relief was ultimately denied. On appeal to the Supreme Court, Petitioner challenged all of the district court's denials pertaining to the interview and deposition of jurors and key witnesses so that he could mount a successful appellate petition for relief. The Supreme Court found that the district court did not abuse its discretion in denying Petitioner's requests. The Court affirmed the district court's decision on all issues. View "Hall v. Idaho" on Justia Law

Petitioner Zack Fields appealed the dismissal of his application for post conviction relief. In 1988, Petitioner was sentenced to death for the stabbing death of Mary Vanderford. Petitioner argued that he was wrongly accused and that DNA test results and affidavits of trial witnesses supported his argument. The district court ordered nineteen latent fingerprints from the murder scene to be run through the national fingerprint database and to have DNA testing of substances found on Petitioner and the victim’s clothing and underneath her fingernails. Testing determined that the fingerprints did not belong to Petitioner, nor did any of the substances contain his DNA. On appeal to the Supreme Court, Petitioner argued that he was entitled to an inference that the victim scratched her attacker because the attacker was close enough to stab her. With no DNA evidence of Petitioner recovered from the murder scene, Petitioner contended the district court erred by not viewing the DNA and fingerprint evidence “in a light most favorable to” Petitioner. The Supreme Court found that there was “nothing but speculation supporting the claim that the scrapings from the victim’s fingernails came from her attacker. We therefore uphold the dismissal of [Petitioner’s] claim . . . because the DNA test results, in light of all admissible evidence, do not demonstrate that [Petitioner] is not the person who committed the murder.” View "Fields v. Idaho" on Justia Law

Plaintiff-Appellant James Wylie owned a subdivision in the City of Meridian. He sought a declaration from the district court that the City and the Idaho Transportation Department improperly denied access for his property directly onto a nearby state highway. The district court dismissed Plaintiff’s complaint on the ground that he failed to present a “justiciable issue.” The Supreme Court’s review of the record revealed that Plaintiff acquired the land in question subject to certain conditions recorded in the plat for the subdivision. The plat listed plainly that “the subject property does have frontage along [the state highway] but . . . not direct access [to the highway].” The Court reasoned that Plaintiff failed to bring an issue for the Court to resolve since Plaintiff’s recorded deed clearly listed the frontage road as access to his property. Therefore, the Court reasoned that the case was “non-justiciable” and affirmed the lower court’s decision to dismiss Plaintiff’s case. View "Wylie v. Idaho Bd of Transportation" on Justia Law

A State trooper arrested Respondent Jason Miller for DUI. The trooper observed that Respondent’s pupils were dilated and asked that Respondent perform some field sobriety tests, which Respondent ultimately failed. The trooper discovered scissors in Respondent’s pocket that were used for cleaning a marijuana pipe. Respondent admitted to smoking marijuana “every day.” The trooper took respondent to a hospital for a urine test, but at the hospital, Respondent refused to willingly provide a sample. A registered nurse at the hospital then catheterized Respondent at the trooper’s request, and extracted the sample. Respondent later pled guilty to possession of drugs, drug paraphernalia and to DUI. Respondent appealed the trial court’s grant of summary judgment to the State. He argued that his civil rights under 42 U.S.C 1983 and state tort laws were violated when he was “unreasonably” catheterized. The Supreme Court found that because “American search-and-seizure law is undeveloped as to when an officer may administer an involuntary warrantless catheterization on a suspect,” the state trooper was entitled to qualified immunity for both of Respondent’s the federal and state law claims. View "Miller v. Idaho State Patrol" on Justia Law