Justia Idaho Supreme Court Opinion Summaries

The defendant was arrested for possession of controlled substances in late December 2021 and released on his own recognizance. The State filed an Information in January 2022, charging him with possession of heroin, methamphetamine, and drug paraphernalia. Due to the COVID-19 pandemic, jury trials in Bingham County were suspended until late February 2022, creating a backlog of cases. The defendant’s trial was rescheduled multiple times, primarily because of delays in forensic testing and the unavailability of a forensic analyst. The district court repeatedly warned that older cases and limited judicial resources might further delay the trial. Ultimately, the defendant’s trial did not occur within the six-month statutory period, and he moved to dismiss the case, arguing violations of his statutory and constitutional speedy trial rights.The District Court of the Seventh Judicial District denied the motion to dismiss, finding good cause for the delay due to the backlog of cases resulting from the pandemic and the need to prioritize older cases. The court also noted that the defendant was not in custody, which lessened the prejudice from the delay. The defendant entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the denial of his motion to dismiss.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court erred in denying the motion to dismiss under Idaho Code section 19-3501 and Article I, section 13 of the Idaho Constitution. The Supreme Court held that court congestion resulting from the COVID-19 pandemic constituted good cause for the trial delay under the statute. The Court also rejected the argument that the Idaho Constitution provides greater protection than the federal constitution regarding speedy trial rights, reaffirming the use of the Barker v. Wingo factors. The judgment of conviction was affirmed. View "State v. Fierro-Garcia" on Justia Law

The case concerns a man who was convicted of first degree murder with a deadly weapon enhancement and resisting and obstructing an officer after his uncle was found fatally stabbed in the home they shared. The defendant was located by police shortly after the incident, with injuries and physical evidence linking him to the crime. During jury selection, the only Black juror in the venire was removed by the prosecution using a peremptory strike, prompting the defendant, who is also Black, to raise a Batson challenge alleging racial discrimination. The trial court denied the challenge, finding the State’s reasons for the strike—juror distraction due to personal circumstances and apparent disengagement—were race-neutral and not pretextual. The jury ultimately found the defendant guilty, and he was sentenced to 40 years to life.The Idaho Court of Appeals affirmed the conviction, holding that the defendant had not established a prima facie case of discriminatory intent under Batson v. Kentucky. The defendant then sought review by the Supreme Court of the State of Idaho, arguing that the trial court erred in denying his Batson challenge, limiting cross-examination about alternate perpetrators, and restricting his closing argument. He also invoked the doctrine of cumulative error.The Supreme Court of the State of Idaho clarified that, under Hernandez v. New York, once the prosecution offers a race-neutral explanation and the trial court rules on discriminatory intent, the initial prima facie showing under Batson is moot. The court found no clear error in the trial court’s acceptance of the State’s race-neutral reasons for the peremptory strike. The court also held that the trial court did not abuse its discretion in limiting cross-examination or closing argument, and found no cumulative error. The judgment of conviction was affirmed. View "State v. Buck" on Justia Law

The case concerns a woman who was convicted and sentenced to death in 1993 for the murders of her husband and two children, whom she killed by setting their apartment on fire while they slept. Investigators found evidence of premeditation, including the use of accelerants, disabled smoke detectors, and severed power to the apartment. The defendant was the beneficiary of several life insurance policies on the victims. After her conviction, she pursued multiple avenues of post-conviction relief in both state and federal courts over the next three decades, raising various claims, including ineffective assistance of counsel.After her initial conviction and sentencing in Ada County, the defendant filed her first post-conviction petition, which was denied by the district court. The Idaho Supreme Court affirmed, finding that her trial counsel had conducted reasonable investigation and that she failed to show prejudice. In subsequent years, she filed several more post-conviction petitions in state court and two federal habeas corpus actions, all of which were unsuccessful. Notably, her claim that trial counsel failed to investigate and present evidence of her alleged brain damage was not raised until her second post-conviction petition, which the Idaho Supreme Court found to be untimely under Idaho Code section 19-2719, as the claim could have been raised earlier.The Supreme Court of the State of Idaho reviewed her sixth post-conviction petition, in which she again argued ineffective assistance of trial and post-conviction counsel, and contended that recent federal case law (Shinn v. Ramirez) should allow her to relitigate her claims. The Idaho Supreme Court held that Idaho Code section 19-2719 strictly limits post-conviction claims to those raised within forty-two days of the death sentence, unless the claims were not and could not reasonably have been known. The court concluded that neither changes in federal law nor alleged ineffective assistance of post-conviction counsel excused her untimely filing, and affirmed the district court’s summary dismissal of her petition as time-barred. View "Row v. State" on Justia Law

Police officers responded to a call regarding an individual, McGuire, at a convenience store in Idaho Falls. After determining he was homeless and possibly under the influence, officers took him to a hospital for medical clearance and then to a behavioral health crisis center, where admission is voluntary. When McGuire failed to complete intake paperwork and did not leave when asked, officers attempted to escort him out. A physical altercation ensued, resulting in injuries to both officers. McGuire was charged with felony battery on a law enforcement officer and misdemeanor resisting or obstructing an officer. At trial, the evidence included officer testimony and body camera footage. McGuire did not testify and argued the State had not met its burden of proof.The Seventh Judicial District Court of Idaho denied McGuire’s motion for mistrial, which was based on statements by the prosecutor during closing argument that allegedly shifted the burden of proof to the defendant. The jury found McGuire guilty on both counts. McGuire was sentenced to one year fixed for the felony and fined for the misdemeanor. The Idaho Court of Appeals affirmed both convictions, and McGuire sought further review.The Supreme Court of the State of Idaho reviewed the case, giving due consideration to the Court of Appeals but directly reviewing the trial court’s decisions. The Supreme Court held that there was sufficient evidence to support the conviction for battery on a law enforcement officer, as officers were performing their duties when responding to the crisis center. However, the Court found insufficient evidence to support the conviction for resisting or obstructing an officer, as the State failed to prove the officers’ actions were lawful and authorized under the relevant statute. The Court also held that, although the prosecutor’s comments constituted misconduct, the trial court’s prompt corrective actions and jury instructions cured any resulting error. The Supreme Court affirmed the felony conviction and denial of the mistrial motion, but vacated the misdemeanor conviction. View "State v. McGuire" on Justia Law

Two men, including the defendant, traveled through Idaho seeking welding work. The defendant owned mobile welding equipment, which he allowed his companion to use for practice in a rural area. After helping set up the equipment, the defendant returned to his truck to nap while his companion welded. During this time, a fire ignited, spreading rapidly and causing significant property damage, including the destruction of homes and grassland. Both men were cited for violating Idaho’s statute prohibiting the willful or careless setting of fires on timber or prairie lands.The case proceeded to trial in the Magistrate Court of Power County, where the State presented evidence that the defendant enabled and facilitated the welding activity in dry, windy conditions, and failed to take adequate precautions to prevent fire. The defendant moved for acquittal twice, arguing that he neither directly ignited the fire nor acted with the requisite criminal negligence. The magistrate court denied both motions, and the jury found the defendant guilty. The defendant was sentenced to a suspended jail term, probation, community service, and restitution. On appeal, the District Court of the Sixth Judicial District affirmed the conviction, finding sufficient evidence of carelessness and upholding the jury instructions.The Supreme Court of the State of Idaho reviewed the case, applying a proximate cause standard to the statutory language “cause to be set on fire.” The Court held that the statute requires proof that the defendant’s actions proximately caused the fire and that he acted with criminal negligence, defined as gross negligence or reckless disregard for the safety of others. The Court found sufficient evidence to support the jury’s verdict under this standard and affirmed the district court’s decision upholding the conviction. View "State v. Frias" on Justia Law

A 33-year-old man was convicted after engaging in sexually explicit communications and sexual intercourse with a 13-year-old girl, whom he met through messaging apps. The girl’s mother discovered the communications and contacted law enforcement, leading to the man’s arrest after he arrived at a prearranged meeting spot set up by police. Forensic evidence linked the man to the crime. He was charged with lewd conduct with a minor and, following a jury trial, was found guilty and sentenced to life in prison with twenty years fixed.After his conviction, the man appealed his sentence, but the Idaho Court of Appeals affirmed the judgment. He then filed a petition for post-conviction relief, alleging ineffective assistance of counsel. The district court appointed post-conviction counsel but later issued a notice of intent to dismiss the petition for failure to state a prima facie claim. The man did not respond, and the district court dismissed the petition. His counsel filed a notice of appeal. The man, acting pro se, filed several motions, including a motion for extension of time to amend his petition, a motion to remove counsel, and a motion for relief from judgment under Idaho Rule of Civil Procedure 60(b)(6), arguing that his counsel had abandoned him. The district court denied these motions, primarily because the man was still represented by counsel and the motions were procedurally deficient.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in denying the motion for extension of time, finding no extraordinary circumstances or attorney abandonment. The court also affirmed the denial of the Rule 60(b)(6) motion on the unchallenged procedural ground that the motion was not properly noticed for a hearing. The district court’s orders were affirmed. View "Smith v. State" on Justia Law

A man was involuntarily committed to the custody of Idaho’s Department of Health and Welfare under a state statute governing civil mental health commitments. After his commitment, hospital staff requested police assistance to transport him to another facility. When officers arrived, the man was cooperative and followed all instructions. Before placing him in the patrol car, an officer conducted a search for weapons. During this search, the officer felt an item in the man’s pocket that he suspected was drug-related, not a weapon. The officer reached into the pocket and found a small bag containing methamphetamine, leading to a felony drug possession charge.The Fifth Judicial District Court of Idaho reviewed the man’s motion to suppress the methamphetamine evidence, arguing that the search violated his Fourth Amendment rights. The district court found that the man was cooperative, showed no signs of being armed or dangerous, and that the officer did not have reasonable suspicion to believe he was carrying a weapon. The court concluded that the search was not justified under any recognized exception to the Fourth Amendment’s warrant requirement and granted the motion to suppress. The State’s subsequent motion for reconsideration was denied.On appeal, the Supreme Court of the State of Idaho considered whether the warrantless search of a person in civil protective custody under Idaho Code section 66-329 was permissible under the Fourth Amendment. The court held that the State failed to show the search fell within a well-recognized exception to the warrant requirement or was otherwise reasonable. The court clarified that the “community caretaking” function is not a standalone exception to the warrant requirement and that neither the search incident to arrest nor the special needs exception applied here. The Supreme Court of Idaho affirmed the district court’s order suppressing the evidence. View "State v. Adams" on Justia Law

In the early morning of January 8, 2021, two individuals dressed in black entered Samuel Johns' residence. Patrycia Labombard, a visitor, witnessed one of the assailants armed with a handgun and described one as a young woman. Labombard was restrained with zip ties but managed to hide in the bathroom. She heard a fight, gunshots, and then the assailants leaving. Johns was found with gunshot wounds and later died. Police interviews with witnesses and family members pointed to Clyde Ewing and his son Demetri as suspects, motivated by a dispute over a stolen pistol and backpack. Evidence collected included surveillance footage, physical evidence from the crime scene, and items found in the suspects' motel room.The District Court of the Second Judicial District of Idaho charged Clyde with first-degree felony murder. Clyde filed motions to dismiss based on his right to a speedy trial, which were denied by the district court, citing COVID-19 related delays as good cause. The court also admitted a video interview of a deceased witness and a compilation video prepared by a police officer, despite Clyde's objections. Clyde was found guilty by a jury and sentenced to life in prison without parole.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the COVID-19 pandemic constituted good cause for trial delays, thus not violating Clyde's right to a speedy trial. The court also found that while the admission of the deceased witness's video interview violated the Confrontation Clause, the error was harmless given the overwhelming evidence against Clyde. Additionally, the court ruled that the compilation video was properly admitted as it summarized voluminous recordings that could not be conveniently examined in court. The cumulative error doctrine did not apply as only one error was identified, which was deemed harmless. View "State v. Ewing" on Justia Law

In the early morning of January 8, 2021, two individuals dressed in black entered Samuel Johns' residence. Patrycia Labombard, a visitor, saw the intruders, one of whom was armed with a handgun. She described one as a teenaged girl or young woman. Labombard was restrained with a zip tie but managed to escape and hide. She heard a fight, yelling, and gunshots. After the intruders left, she found Johns with gunshot wounds. Johns died from his injuries. Police interviewed witnesses, including Johns' mother, Debra Moffat, and family members who suspected Clyde Ewing and his son, Demetri Ewing, due to an ongoing dispute over a stolen pistol and backpack. Surveillance footage showed two individuals on bikes near Johns' house. Clyde and Demetri were arrested, and a search of their motel room revealed incriminating evidence.The District Court of the Second Judicial District of Idaho denied Demetri's motion to suppress evidence obtained from the search and arrest warrants, finding probable cause. The court also admitted statements from Moffat, who had died before trial, over Demetri's hearsay objections. Demetri was found guilty of first-degree felony murder and sentenced to life in prison with 25 years fixed.The Supreme Court of Idaho reviewed the case. The court affirmed the district court's denial of Demetri's motion to suppress, finding sufficient probable cause for the search and arrest warrants. The court also found that Demetri was not entitled to a Franks hearing, as he failed to show that any omissions or misstatements in the warrant affidavits were made intentionally or recklessly. However, the court agreed that admitting Moffat's statements violated the Confrontation Clause but concluded that this error did not affect the trial's outcome due to the substantial evidence against Demetri. The Supreme Court of Idaho affirmed the district court's judgment of conviction. View "State v. Ewing" on Justia Law

Kevin Keith Bell was convicted of rape, witness intimidation, and felony domestic battery. He filed a pro-se petition for post-conviction relief, alleging prosecutorial misconduct, actual innocence, and ineffective assistance of counsel. Bell later filed an amended petition through counsel, focusing on three specific instances of ineffective assistance of counsel. The State moved for summary dismissal of the amended petition, which the district court granted. Bell then filed a motion for reconsideration, arguing the district court erred in dismissing his amended petition on grounds not raised by the State. The district court denied the motion.The district court of the Fifth Judicial District of Idaho initially handled Bell's case. After the State moved for summary dismissal, the district court granted the motion, finding Bell had not provided sufficient legal argument to support his claims of ineffective assistance of counsel. Bell's motion for reconsideration was also denied, as the district court concluded that the State had indeed argued the grounds for dismissal and that Bell had failed to demonstrate a genuine issue of material fact.The Supreme Court of the State of Idaho reviewed the case. The court held that Bell failed to preserve his argument regarding the lack of notice for the dismissal of his original claims because he did not raise this issue in his motion for reconsideration. The court also affirmed the district court's dismissal of Bell's claim that his trial counsel was ineffective for failing to inquire into an allegedly biased juror, as Bell did not provide sufficient evidence of actual bias or resulting prejudice. Consequently, the Supreme Court affirmed the district court's judgment dismissing Bell's petition for post-conviction relief. View "Bell v. State" on Justia Law