Justia Idaho Supreme Court Opinion Summaries

Plaintiff-appellant Robert Stark appealed the dismissal of his petition for post-conviction relief. Stark alleged his trial counsel rendered ineffective assistance for failing to file a motion to suppress the contents of a backpack that was searched incident to Stark’s arrest. The district court dismissed Stark’s ineffective assistance of counsel claim, finding Stark did not show deficient performance or prejudice. The district court found that even if a motion to suppress had been filed, it would have been denied, either because Stark disclaimed ownership of the backpack before it was searched or because the contents of the backpack would have been inevitably discovered. Stark challenged the district court’s ruling by arguing that a motion to suppress would have been granted because: (1) the backpack was not lawfully searched incident to his arrest; (2) the contents of the backpack would not have been inevitably discovered; and (3) his disclaimer of ownership was legally ineffective. Stark thereafter appealed to the Court of Appeals, which affirmed the dismissal. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed it. View "Stark v. Idaho" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on whether the Idaho Constitution protects abortion from the legislature's broad power to enact laws concerning the public’s health, welfare, and safety. Planned Parenthood Great Northwest, Hawaii, Alaska, Indiana, Kentucky, and Caitlin Gustafson, M.D., on behalf of herself and her patients (collectively “Petitioners”), brought three petitions, each seeking a writ of prohibition and declaratory relief blocking implementation and enforcement of recently enacted laws in Idaho. Petitioners also raised various facial challenges, claiming these laws offend important constitutional principles, such as equal protection, due process, the special laws provision, the separation of powers doctrine, and purported “informational privacy” protections under the Idaho Constitution. Petitioners further claimed that the Idaho Human Rights Act limited the legislature’s ability to regulate abortion through the Total Abortion Ban and 6-Week Ban. After careful consideration of the issued raised, the Idaho Supreme Court denied Petitioners’ requests for extraordinary writs of prohibition and declaratory relief. View "Planned Parenthood Great Northwest, et al. v. Idaho" on Justia Law

Jessie Adams appealed an order to pay $15,053.49 in restitution stemming from his conviction of petit theft. The State charged Adams with two separate counts of grand theft. A jury found Adams guilty of the first charge of grand theft; as to the second charge, the jury acquitted Adams of grand theft but found him guilty of the lesser-included offense of petit theft. The district court ordered Adams to pay $15,053.49 in restitution related to his conviction for petit theft. Adams argued the district court had abused its discretion in ordering restitution in an amount greater than $999.99, “the amount associated with the statutory delineation between grand theft and petit theft.” The Idaho Supreme Court concurred the district court abused its discretion by ordering restitution in excess of $1000. The judgment was therefore vacated and the matter remanded for further proceedings. View "Idaho v. Adams" on Justia Law

Chad Schiermeier appealed the summary disposition of his petition for post-conviction relief. In 2017, Schiermeier was charged and convicted of one count of grand theft for stealing money from the Blaine County Sheriff’s DARE program. Schiermeier, a Blaine County Deputy Sheriff, had been the manager of the program for several years and had spent large sums of the program’s money on various items for his personal use. Schiermeier appealed his conviction and sentence to the Idaho Supreme Court, which then affirmed. In 2020, Schiermeier, through the same private attorney who had represented him during his trial, petitioned for post-conviction relief, arguing that his appellate counsel (a Deputy State Appellate Public Defender) had been ineffective for failing to raise several issues in his direct appeal. The State moved for summary disposition, which the district court granted. Schiermeier timely appealed. Finding no reversible error, the Supreme Court affirmed the district court’s summary disposition of Schiermeier’s petition for post-conviction relief. View "Schiermeier v. Idaho" on Justia Law

Kathryn Adkins appealed her conviction for felony concealment of evidence. Whether the crime of concealment of evidence was a felony depends on whether the investigation or trial to which the evidence related involved a misdemeanor offense or a felony offense. Because the felony status of the underlying offense was a “fact” that increases the maximum sentence that may be imposed, Adkins argued that in a jury trial this must be decided by the jury, not the judge. To this the Idaho Supreme Court disagreed and affirmed the judgment of conviction. The sentence imposed by the district court, however, exceeded the maximum permitted under Idaho Code section 18-2603. The sentence was vacated and remanded for entry of a corrected sentence. View "Idaho v. Adkins" on Justia Law

Darin Ogden was convicted on one count of sexual exploitation of a child and one count of sexual battery. Ogden argued the convictions should have been vacated because of several erroneous evidentiary rulings made by the district court, which deprived Ogden of his constitutional right to confront witnesses and present a defense. Alternatively, Ogden argued his sentences should have been vacated because the court considered unreliable information related to earlier conduct for which he had been acquitted. Ogden also requested that the presentence investigation report be redacted to omit those allegations. The Idaho Supreme Court determined that although the district court did not abuse its discretion by denying Ogden’s first Rule 412(b) motion seeking to introduce evidence of V.H.’s (the victim) sexual history with Michael Roller, it abused its discretion by denying Ogden’s second Rule 412(b) motion seeking to introduce evidence of V.H.’s sexual history with Ty Birchfield. The Court affirmed Ogden's conviction for sexual battery, but vacated his conviction for sexual exploitation of a child, and the case was remanded for a new trial. View "Idaho v. Ogden" on Justia Law

Police apprehended defendant Clarence Lancaster for questioning relating to several ATM thefts in Boise, Idaho. He was later charged and ultimately entered conditional guilty pleas to two felonies: burglary and grand theft. This appeal arose from the denial of his motion to suppress. Lancaster argued that his confession and other evidence should have been suppressed because the arresting officers violated Idaho Code section 19-608 by failing to tell Lancaster the basis of his arrest. He maintains that this statutory violation rendered his arrest an unreasonable seizure under Article 1, Section 17 of the Idaho Constitution. He also argues that the district judge abused its discretion at sentencing by failing to strike an attachment to the Presentence Investigation Report. Finding no reversible error, the Idaho Supreme Court affirmed Lancaster's conviction. View "Idaho v. Lancaster" on Justia Law

On April 24, 2019, Deputy Brott stopped defendant-appellant Arthur Vivian’s car because Vivian’s brake lights were not working. Brott recorded the stop using a body camera. Vivian informed Brott that his license had been suspended and Brott began investigating the reason for Vivian’s suspended license. After five minutes and forty seconds of interaction with Vivian, Brott returned to his vehicle to run Vivian’s license. Brott talked to Officer Short, who had recently arrived at the scene. Short advised Brott that there was a possibility there could be narcotics in Vivian’s vehicle. Brott called for a drug detecting K-9 unit nine minutes into the stop. Brott exited his patrol car with the completed citation and Vivian’s license at sixteen minutes and forty-six seconds into the stop. Deputy Hickam and a drug detecting K-9 arrived eighteen minutes and thirty-seven seconds into the stop. At nineteen minutes and twenty-nine seconds Brott approached Vivian’s vehicle, asked Vivian to exit the vehicle and requested to pat him down. Brott issued the suspended license citation at twenty minutes and forty seconds. During the time Brott explained the citation to Vivian, the drug K-9 alerted to a controlled substance in the vehicle. A subsequent search discovered a bag containing methamphetamine. Vivian appealed the district court’s denial of his motion to suppress evidence obtained following his traffic stop, arguing the stop was unlawfully extended, and statements made before and after the delay were gathered in violation of his Fourth Amendment rights. The State contended that evidence of the drugs would have been inevitably discovered, and thus statements made relating to those drugs were admissible under the same doctrine. The Idaho Supreme Court rejected that argument, finding verbal statements were different than physical evidence "because a defendant could choose, if given time for reflection, not to make the statements or to answer differently." The Court held the inevitable discovery exception did not apply to statements that would otherwise be excluded as “fruit of the poisonous tree.” The district court’s decision that Vivian’s post-Miranda statements were admissible was reversed, Vivian’s judgment of conviction was vacated, and the case was remanded for further proceedings. View "Idaho v. Vivian" on Justia Law

Probation officers detained Natalie Miramontes while conducting a residence check on a female probationer, Christine Evans. During the detention, probation officers searched Miramontes’ purse and found suspected drug paraphernalia. Probation officers paused the search and contacted police. Once police arrived, officers resumed the search and, inside a pantry converted to a spare bedroom, they uncovered more drug paraphernalia and a substance that tested presumptively positive for methamphetamine. Miramontes told police she had been sleeping inside the spare room. Miramontes moved to suppress all evidence found during her detention. The district court denied her motion. Miramontes entered a conditional guilty plea and reserved her right to appeal. She appealed, and the Court of Appeals affirmed her conviction. Miramontes petitioned the Idaho Supreme Court for review, arguing the district court erred when it denied her motion to suppress because officers searched her purse without reasonable and articulable suspicion. She also argued the items found during the later search of the spare bedroom would not have been inevitably discovered without the unlawful search of her purse. The Supreme Court reversed the district court’s decision denying Miramontes’ motion to suppress and remanded for fact-finding on whether Miramontes was unlawfully searched. View "Idaho v. Miramontes" on Justia Law

At issue in this appeal was a question of the due process rights of an unwed biological father who had established a relationship with his two-month-old child through frequent visits before the child’s maternal grandfather filed a petition to adopt the child. Under Idaho Code sections 16-1504 and 16-1513, the magistrate court determined that the grandfather’s filing of the adoption petition permanently and irrevocably barred the father from establishing paternity or objecting to the adoption. The Idaho Supreme Court vacated the magistrate court's decision because the father’s relationship with his child may have been sufficient to confer parental rights protected by the due process provisions of the Fourteenth Amendment of the United States Constitution, and the statutes relied upon in the magistrate court’s decision unconstitutionally risk termination of these rights without due process. View "Jane Doe I & John Doe I" on Justia Law