Justia Idaho Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Thomas Cartwright his conviction for felony enticing a child through the use of the internet. Police arrested Cartwright outside a 7-11 convenience store, where he was attempting to meet a 14-year-old girl with whom he had been exchanging sexual messages. In reality, the girl was an undercover detective. Cartwright argued on appeal the district court erred when it denied his motion to dismiss because Idaho Code section 18- 1509A was unconstitutionally overbroad on its face. Cartwright also argued the district court erred when it refused to instruct the jury on entrapment. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Cartwright" on Justia Law

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Justin Lee Anderson appealed his convictions for lewd and lascivious conduct with a minor under the age of sixteen, sexual abuse of a child under the age of sixteen, and multiple counts of sexual exploitation of a child. He challenged the district court’s denial of his motion to sever, admission of Rule 404(b) evidence against him, and delivery of a jury instruction on deliberation that varied from the standard instruction. After review, the Idaho Supreme Court affirmed the district court’s denial of Anderson’s motion to sever but reversed the district court’s evidentiary rulings with respect to admitting Rule 404(b) evidence against Anderson. The errors in admitting this evidence were not harmless, and, as such, the Court vacated Anderson’s judgment of conviction and remanded this matter for a new trial. View "Idaho v. Anderson" on Justia Law

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Defendant-respondent Dale Sutterfield stole a cell phone owned by a restaurant in Garden City, Idaho. A restaurant employee and his co-worker confronted Sutterfield, recovered the cell phone, and subsequently contacted the Garden City police for assistance. After the police arrived, the restaurant employee signed an affidavit and citizen’s arrest form. The police arrested Sutterfield for petit theft and conducted a search incident to arrest. During their search, the police found a small quantity of methamphetamine. Sutterfield was also arrested for felony possession of a controlled substance. Sutterfield moved to suppress the methamphetamine evidence, asserting his arrest and the search incident to that arrest violated his rights under the Fourth Amendment to the United States Constitution and Article I, Section 17 of the Idaho Constitution. After determining that Sutterfield had been arrested by a peace officer for a completed misdemeanor that occurred outside of the officer’s presence in violation of the Idaho Constitution, the district court granted Sutterfield’s motion to suppress. The district court dismissed the felony count of possession of a controlled substance, and Sutterfield pleaded guilty to the misdemeanor count of petit theft. The State timely appealed dismissal of the felony charge. The Idaho Supreme Court reversed, finding that the citizen’s arrest did not offend the Idaho Constitution, and defendant's arrest was not one by a peace officer for a completed misdemeanor that occurred outside of the officer’s presence. Therefore, the Court held the search-incident-to-an-arrest exception applied. Police were not precluded from conducting a warrantless search of Sutterfield after placing him under citizen’s arrest. Moreover, the evidence obtained by the officer during the search incident to the citizen’s arrest was not subject to the exclusionary rule. Therefore, the district court erred when it granted Sutterfield’s motion to suppress. View "Idaho v. Sutterfield" on Justia Law

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During a traffic stop, police confiscated a pipe, a bong, and some marijuana possessed by defendant-appellant Richard Heath. Heath was charged with misdemeanor possession of marijuana and misdemeanor possession of drug paraphernalia. Heath moved to suppress the pipe and bong as evidence against him and the magistrate court granted the motion. Heath also moved for the return the pipe and the bong under Idaho Criminal Rule 41(f), but the magistrate court denied the motion after holding that the pipe and bong were contraband. Heath appealed the denial of his motion to the district court, which affirmed. Finding no reversible error, the Idaho Supreme Court also affirmed. View "Idaho v. Heath" on Justia Law

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In 2004, a jury found Azad Haji Abdullah guilty of first-degree murder, first-degree arson, three counts of attempted first-degree murder, and felony injury to a child. He was sentenced to death for the murder. Abdullah filed a petition for post-conviction relief, which was dismissed by the district court in 2011. Abdullah then filed a consolidated appeal that included a direct appeal from his convictions and sentences and an appeal from the district court’s dismissal of his petition for post-conviction relief. The Idaho Supreme Court, in Idaho v. Abdullah, 348 P.3d 1 (2015), affirmed the convictions, sentences, and denial of post-conviction relief. In 2013—after the district court issued its order dismissing the petition for post-conviction relief, but prior to the Supreme Court’s issuance of Abdullah in 2015—Abdullah filed a successive petition for post-conviction relief. The Successive Petition was amended in 2016 and 2017. Abdullah also filed a pro se supplement to the successive petition that was incorporated with the successive petition. The successive petition and supplement included substantive claims, claims of ineffective assistance of trial counsel, and claims of ineffective assistance of appellate counsel. The district court determined that Abdullah was not entitled to post-conviction relief and summarily dismissed his successive petition and Supplement. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s dismissal. View "Abdullah v. Idaho" on Justia Law

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The plaintiffs were indigent defendants represented in criminal actions by attorneys provided through Idaho’s public defense system. They alleged that numerous inadequacies in Idaho’s public defense system, as administered by the State and the Idaho Public Defense Commission (“PDC” or together “Respondents”), violated the rights of the named plaintiffs, as well as those of similarly situated criminal defendants across Idaho, under the Sixth and Fourteenth Amendments to the U.S. Constitution and Article I, Section 13 of the Idaho Constitution. In 2019, the district court denied cross motions for summary judgment, citing a lack of precedent as to the controlling legal standard to be applied, and requested this appeal. The Idaho Supreme Court granted the district court’s request for permissive appeal to determine the standard of review. The central issue presented for the Supreme Court's review centered on how to properly evaluate the deficiencies in Idaho’s public defense systems alleged by Appellants. In sum, Appellants insisted that a broader view was sufficient, while Respondents demanded the district court examine this issue closely. The Supreme Court held that both views were necessary: "a close up view, which allows for greater specificity, must be applied to the individual claims of at least one of the named plaintiffs whose allegations formed the basis of standing; however, a more distant view, which allows for greater overall perspective, is permissible for the examination of the systemic constitutional shortcomings alleged by Appellants." View "Tucker v. Idaho" on Justia Law

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While responding to a call regarding an ongoing robbery at a mobile home park in Grangeville, Idaho, officers with the Grangeville Police Department interacted with defendant-appellant William Clark. Upon learning that Clark had an outstanding warrant for his arrest in Nez Perce County, Idaho, the officers attempted to arrest him. Clark fled, first entering a nearby home where the owner of the home implored him to leave. After exiting the first home, Clark entered the home next door, successfully evading the officers for approximately ten minutes. The officers eventually located Clark, hiding underneath a bed in the second home, where he was arrested. After a bench trial, the district court found Clark guilty on both counts of felony unlawful entry, concluding that the officers’ pursuit to execute the arrest warrant constituted “fresh pursuit” as defined in Idaho Code section 19-705. Clark appealed, arguing that pursuit to execute an outstanding warrant did not fall under either the common law or statutory definition of “fresh pursuit.” As a result, Clark argued the State failed to present sufficient evidence of the pursuit element for felony unlawful entry. Finding that "fresh pursuit," as defined in section 19-705 included pursuit to execute an arrest warrant, the Idaho Supreme Court affirmed Clark's conviction. View "Idaho v. Clark" on Justia Law

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Defendant Melonie Smith appealed her conviction for first degree murder and destruction, alteration, or concealment of evidence. On appeal, Smith claimed the district court: (1) erred when it denied her motion to suppress; (2) abused its discretion when it admitted certain testimony over her objection; and (3) committed fundamental error by (a) admitting a video and (b) not striking the prosecutor’s comments in closing arguments. Smith further argued she was deprived of her right to a fair trial due to the accumulation of errors. Finding no reversible error, the Idaho Supreme Court affirmed her convictions. View "Idaho v. Smith" on Justia Law

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Fifteen-year-old Lucas Orozco was charged with robbery and burglary, both felonies, for allegedly robbing a convenience store. After a magistrate court determined there was probable cause to charge Orozco with the felonies, it waived juvenile jurisdiction and bound him over to district court as an adult pursuant to Idaho Code section 20-509. Orozco objected to this automatic waiver, filing a motion with the district court challenging the constitutionality of section 20-509. The district court denied the motion, relying on precedent from the Idaho Court of Appeals, which previously upheld the constitutionality of section 20-509. Orozco appealed, arguing that the automatic waiver denied him procedural due process protections afforded to him by the U.S. Constitution. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Orozco" on Justia Law

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In this appeal, the Idaho Supreme Court was asked to clarify the meaning and extent of a defendant’s Sixth Amendment right to conflict-free counsel. Appellant Alfredo Alvarado argued his rights were violated because his public defender had previously represented a witness who was adverse to him on a felony charge. After disclosing the conflict, Alvarado’s attorney agreed that he and the public defender’s office would decline any future representation of the witness. However, Alvarado argued that counsel continued to have an actual conflict of interest because his ongoing ethical duties to the witness and former client prevented him from effectively cross- examining the witness. Alvarado contended this resulted in a structural defect in the trial, which necessitated overturning his convictions. In the alternative, Alvarado argued his unified aggregate sentence of twenty years to life for attempted strangulation and domestic abuse was excessive. After review, the Supreme Court determined Alvarado failed to show his counsel's representation constituted a fundamental error. He neither demonstrated an error affected the outcome of the trial, nor shown that a structural error denied him the right to counsel during a critical stage of the proceeding. Therefore, the Court ruled Alvarado was not deprived of his Sixth Amendment right to conflict-free counsel. The Court also held the district court did not abuse its discretion in sentencing Alvarado to a twenty-year to life aggregate sentence on his two felony convictions. View "Idaho v. Alvarado" on Justia Law