Justia Idaho Supreme Court Opinion Summaries

The State appealed a district court's grant of post-conviction relief to Defendant Trevor Booth. Defendant was charged with first-degree murder for the shooting death of Leonard Kellum in 2005. Prior to trial, the prosecutor handling Defendant's case informed Defendant and his counsel that the prosecution intended to request that the trial court provide a special verdict form for the jury if Defendant was convicted of first-degree murder. Specifically, the verdict form would instruct the jury to determine whether certain statutory aggravating circumstances existed. Defendant's attorney interpreted the applicable statute to mean that if the jury were to find any aggravating circumstances, the court would be required to impose a fixed life sentence. Defense counsel prepared a memorandum to Defendant outlining his understanding of the potential penalties. The memorandum went on to explain what Defendant's options were with regard to entering a plea agreement with the State. Defendant eventually pled guilty pursuant to a negotiated plea agreement. Defendant was sentenced to an indeterminate life sentence with thirty years fixed. Defendant timely filed a petition for post-conviction relief, arguing he received ineffective assistance of counsel at trial and in the handling of the plea agreement. The district court concluded that Defendant's counsel erroneously advised him regarding the potential sentence and with regard to the special verdict form. The court withdrew the guilty plea and set the case for a jury trial. The State appealed this decision to the Supreme Court. Upon review, the Court concluded that Defendant met his burden of demonstrating his counsel's performance was deficient and that he was prejudiced as a result. The Court affirmed the district court's decision to grant Defendant's petition for post-conviction relief. View "Booth v. Idaho" on Justia Law

Defendant Richard Hansen appealed the district court's denial of his motion to suppress. He contended that a probationer living in an RV on Defendant's property lacked actual or apparent authority to consent to a search of the common areas in Defendant's home. Defendant asserted that the drugs discovered during that search should have been suppressed, along with additional evidence seized pursuant to a search warrant the State later obtained. Upon review, the Supreme Court found that since the officers in this case reasonably believed the probationer had apparent authority to consent to the search, the denial of Defendant's motion to suppress was properly decided. View "Idaho v. Hansen" on Justia Law

In 2007, a mother walked in on her child and Defendant Jonathan Folk "just playing." She would later learn that Defendant had placed his mouth on the child's penis. The State charged Defendant with lewd conduct. Defendant would be later tried by a jury, found guilty and sentenced to life in prison without parole. Defendant appealed. Principal among his arguments was that the State violated his statutory right to a speedy trial. At issue for the Supreme Court's review was whether the postponement of trial at the defendant's request waived the protection of the speedy trial statute, even if the trial was rescheduled within the proscribed period. The Court found that Defendant's request indeed waives protection of the statute. However, the Court vacated Defendant's conviction on errors by the trial court. The Supreme Court remanded the case for a new trial. View "Idaho v. Folk " on Justia Law

The State appealed a district court's judgment granting Defendant Trevor Booth's petition for post conviction relief on the grounds that Defendant received ineffective assistance of counsel. In 2005, Defendant was accused of the shooting death of Leonard Kellum. Defendant was subsequently charged for first-degree murder. The State declined to seek the death penalty in this case. Defendant's attorney prepared a memorandum outlining his understanding of the potential penalties he would face. The attorney discussed the nuances of the statutory aggravating circumstances and the risks associated with taking the case to trial. Defendant then entered into a plea agreement with the State, agreeing to plead guilty first-degree murder. After a failed appeal challenging his sentence, Defendant filed for post-conviction relief. The court concluded that Defendant's attorney erroneously advised Defendant of the consequences of his plea agreement. The Supreme Court found that the district court did not err in concluding that Defendant's attorney was deficient, and that Defendant was prejudiced as a result. The Court affirmed the district court's decision to grant Defendant post-conviction relief. View "Booth v. Idaho" on Justia Law

Petitioner-Appellant Stan Hawkins appealed a decision by the Bonneville County Board of Commissioners that granted his neighbors Dale and Mary Meyers variances to replace aging homes on two parcels of their land. The parcels in question were originally zoned as agriculture, and each contained homes built before the 1940s. People living on the Meyers' land regularly used a road over Mr. Hawkins' land for access. Bonneville County enacted its zoning ordinance in 1959, after the homes on the Meyers' land were built and occupied. The ordinance required dwellings to have frontage along a county-approved road. No easement was ever granted across Mr. Hawkins' land, nor was a public road officially designated to the Meyers' property. The Meyers filed for variances in 2007 believing that they needed to comply with the frontage requirement. At a hearing, the Commissioners found that the Meyers' did not need variances because their property had been "grandfathered in" so that the frontage requirement did not apply. However, the Commissioners granted the variance anyway. A trial court dismissed Mr. Hawkins' petition for review, holding that he did not have standing to file a petition for judicial review, and he did not show that the County had prejudiced any of his substantial rights. Upon review of the trial court record, the Supreme Court found that Mr. Hawkins had standing to pursue his petition for judicial review. However, the Court dismissed his petition because he did not show any prejudice to his substantial rights. Accordingly, the Court affirmed the trial court's order dismissing Mr. Hawkins' petition. View "Hawkins v. Bonneville Cty. Bd. of Commissioners " on Justia Law

Petitioner-Appellant Roger Steele and several residents appealed a district court order that dismissed their claim that the City of Shelley (City) illegally annexed land in Bingham County known as "Kelley Acres." The district court found that there was no statutory authorization for the district court's review of the annexation. On appeal to the Supreme Court, Appellants argued that the annexation was "arbitrary and capricious" and procedurally defective. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court found that there was indeed, no statutory authority for judicial review of the annexation. Furthermore, the Court found substantial evidence that supported the City's annexation of Kelley Acres. The Court affirmed the lower court's decision. View "Steele v. City of Shelley " on Justia Law

Defendant Jonathan Ellington appealed his conviction for murder and aggravated battery. He argued on appeal to the Supreme Court that prosecutorial misconduct, evidentiary errors, a biased jury and the "cumulative error doctrine" entitled him to a new trial. The Supreme Court found merit to several of Defendant's claims. The Court found that the district court abused its discretion when it denied Defendant a new trial after evidence came to light that the State's sole rebuttal witness provided false testimony at trial. The Court vacated Defendant's conviction and sentence, and remanded the case for a new trial. View "Idaho v. Ellington" on Justia Law

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