Justia Idaho Supreme Court Opinion Summaries

The Supreme Court of the State of Idaho vacated a lower court's decision to modify Kenneth Richard Rose, Jr.'s sentence. Rose had pleaded guilty to one count of felony aggravated driving under the influence, and the district court sentenced him to six years in prison with one year fixed. The district court indicated it would reconsider Rose's sentence after his direct appeal and stayed the execution of his sentence. Following the conclusion of Rose's appeal, he moved the district court for a reduction of sentence per Idaho Criminal Rule 35(b). The district court agreed and modified Rose's sentence, leading the State to appeal.The Supreme Court found that the district court did not have jurisdiction to modify Rose's sentence because his Rule 35(b) motion was untimely. The court concluded that the 120-day timeframe for filing a Rule 35(b) motion began when the district court initially entered its judgment, not after Rose's appeal concluded. The court held that the district court's decision to stay the execution of Rose's sentence did not extend the timeframe for filing a Rule 35(b) motion. Thus, because Rose's motion was filed more than three years after his sentence was imposed, exceeding the 120 days permitted by Rule 35(b), the district court did not have jurisdiction to modify his sentence. View "State v. Rose" on Justia Law

The case involves the defendant, Kevin James Van Zanten, who was convicted for felony possession of methamphetamine and misdemeanor driving under the influence. Van Zanten challenged the conviction, arguing that the evidence was obtained unlawfully following a stop of the commercial vehicle he was driving. He claimed the stop was based on regulations adopted by the Idaho State Police, which he argued resulted from an unconstitutional delegation of legislative power.In September 2020, an Idaho State Police Trooper observed a 2005 Kenworth truck driven by Van Zanten. The Trooper noted several violations, including an improperly displayed Department of Transportation number, unsecured hazardous material, and other items on the truck. The truck was stopped, and the driver was identified as Van Zanten, whose driving privileges were found to be suspended. A subsequent search of the truck resulted in the finding of drugs, leading to Van Zanten's arrest.At the trial court, Van Zanten moved to suppress the evidence, arguing that the Trooper had no legal basis to stop him. He asserted that the Trooper initiated the stop to investigate state regulations that were unenforceable because the statutes authorizing those regulations unconstitutionally delegated legislative power. The district court denied his motion, leading to his appeal to the Idaho Supreme Court.The Supreme Court of the State of Idaho affirmed the district court's judgment. It held that the Trooper had reasonable suspicion to stop Van Zanten due to specific, articulable facts, thus justifying the stop. The court noted that the inherent danger associated with unsecured hazardous waste and other violations fell within the community caretaking function of law enforcement, and given the nature of the vehicle Van Zanten was driving, the public interest in safety outweighed the limited intrusion of stopping the vehicle. Consequently, the court did not need to address the constitutionality of the statutes in question. The court affirmed Van Zanten’s judgment of conviction. View "State v. Van Zanten" on Justia Law

In this case, Develin Johnson appealed against the district court's decision that upheld his convictions for domestic battery and false imprisonment. The key issue in the appeal was the admissibility of Johnson's previous misdemeanor conviction for petit theft under Idaho Rule of Evidence 608(b) and whether the probative value of the evidence was substantially outweighed by the risk of unfair prejudice. Johnson argued that the district court erred in affirming the judgment of conviction because his misdemeanor conviction for theft was inadmissible under Idaho Rule of Evidence 608(b) and the probative value of the evidence was substantially outweighed by a danger of unfair prejudice. The Supreme Court of the State of Idaho affirmed the district court's decision, holding that the conduct leading to Johnson's 2013 misdemeanor conviction was probative of his character for truthfulness and that the prejudicial effect of the evidence did not substantially outweigh its probative value. View "State v. Johnson" on Justia Law

In the case before the Supreme Court of the State of Idaho, the appellant, Thomas Eugene Creech, appealed the district court's decision to dismiss his successive post-conviction petition as untimely under Idaho Code section 19-2719. Creech argued that his petition was timely due to the United States Supreme Court’s decision in Shinn v. Ramirez, which he believed represented a triggering event that restarted the forty-two-day period for filing a petition under Idaho Code section 19-2719. Creech was convicted and sentenced to death for the first-degree murder of a fellow prisoner in 1981. He filed multiple appeals and petitions for post-conviction relief, all of which were denied. His current petition relates to his 1995 death sentence.The Supreme Court of the State of Idaho affirmed the district court's decision to dismiss Creech's successive petition as untimely. The court held that the Shinn v. Ramirez judgment did not constitute a triggering event to restart the forty-two-day period for filing a petition under Idaho Code section 19-2719. The court noted that Shinn v. Ramirez interpreted federal law and did not have any bearing on state statutes, such as Idaho Code section 19-2719. Furthermore, the court rejected Creech's argument that the alleged ineffective assistance of his initial post-conviction counsel should excuse his failure to timely raise a trial ineffective assistance of counsel claim. The court held that under existing Idaho law, ineffective assistance of post-conviction counsel does not excuse a failure to raise issues that should have been reasonably known. Therefore, Creech's petition was untimely under Idaho Code section 19-2719. View "Creech v. State" on Justia Law

The Supreme Court of the State of Idaho affirmed the dismissal of a successive post-conviction petition for relief filed by Thomas Eugene Creech, an inmate sentenced to death in 1995 for the murder of fellow inmate David Jensen. The district court had dismissed Creech's petition as untimely under Idaho Code section 19-2719, which requires capital defendants to file any legal or factual challenge to the sentence or conviction that is known or reasonably should be known within forty-two days of the filing of the judgment imposing the death sentence. Creech argued that his death sentence, which was imposed by a judge without the participation of a jury, was unlawful based on the prohibition against cruel and unusual punishment under the U.S. Constitution and the Idaho Constitution. He also claimed that societal norms have evolved to the point where his judge-imposed death sentence is now deemed cruel and unusual punishment. However, the Supreme Court held that Creech failed to articulate a claim based on information he did not know or could not have reasonably known within the forty-two day period, thus upholding the district court's dismissal of his petition as untimely. View "Creech v. State" on Justia Law

The Idaho Supreme Court upheld a conviction of a man named Troy Dale Green for various offenses, including trafficking in methamphetamine and unlawful possession of a firearm. Green appealed his conviction, arguing that the testimony of a detective who had not personally performed the extraction of data from his cellphone violated his rights under the Confrontation Clause of the Sixth Amendment. The court disagreed, ruling that the detective's testimony did not violate Green's rights because the detective had sufficient knowledge and experience to analyze the extracted data and independently conclude that the data came from Green's phone. The court also rejected Green's argument that the text messages from his phone were not properly authenticated under Idaho's rules of evidence. The court found that the detective's testimony, along with that of two other detectives, sufficiently authenticated the text messages. The court affirmed Green's conviction. View "State v. Green" on Justia Law

In the case before the Supreme Court of the State of Idaho, defendant William Parsons was convicted on three felony counts of lewd conduct with a minor under sixteen and one misdemeanor count of disseminating harmful material to a minor. The prosecution's case was largely based on video evidence from two interviews with the minor victim, conducted by a medical social worker at a children's evaluation service that specializes in abuse cases. The victim did not testify at the trial. On appeal, Parsons argued that the admission of the video evidence violated his Sixth Amendment rights under the Confrontation Clause, as he was not given an opportunity to confront his accuser.The court agreed with Parsons, concluding that the videos were submitted to the jury in violation of the Sixth Amendment. The court found that the primary purpose of the victim's interviews was to establish or prove past events potentially relevant to a later criminal prosecution, rather than to provide medical care. Therefore, the statements in the interviews were testimonial in nature. Since the defendant had no prior opportunity to cross-examine the victim, the court held that it was error to admit the videos at trial. The court vacated the conviction and remanded the case for further proceedings consistent with its decision. View "State v. Parsons" on Justia Law

In 2021, Gilberto Flores Rodriguez was found guilty of first-degree murder by a Cassia County jury for the 1995 killing of a 14-year-old girl. After the verdict, Rodriguez filed a motion for a new trial, arguing that the district court abused its discretion by denying his motion for a new trial after information came to light suggesting that a juror may have slept through parts of the trial. Rodriguez's argument was based on the belief that the juror's alleged inattentiveness amounted to juror misconduct and could have prejudiced the defendant. The Supreme Court of the State of Idaho held that Rodriguez failed to meet his burden of establishing by clear and convincing evidence that juror misconduct occurred. The court noted that there was much uncertainty over whether the juror was actually asleep during any stage of the trial. The court further held that even if it were to address the question of prejudice, Rodriguez's motion would still lack evidence. The court concluded that Rodriguez failed to establish the identity and duration of the specific testimony, argument, or instructions the juror missed. As a result, the court affirmed the order of the district court denying Rodriguez’s motion for a new trial. View "State v. Rodriguez" on Justia Law

In the case before the Supreme Court of Idaho, Michael W. Skehan appealed a decision affirming the Idaho Central Sex Offender Registry's ruling that he must register as a sex offender in Idaho. Skehan had been convicted of sexual abuse in the third degree in Oregon in 2001 and later moved to Idaho. He argued that the procedures used by the Registry were improper and that he should not be required to register.The court affirmed the lower court's decision, holding that Skehan failed to demonstrate that the Registry's ruling was deficient under Idaho Code section 67-5279(3). The court also found that Skehan failed to preserve several arguments for appeal, offered little rebuttal to the Registry's position, and did not provide a sufficient record to substantiate his claims on appeal.The court also held that Skehan failed to demonstrate that the Registry's consideration of other information in addition to the Oregon and Idaho statutes was arbitrary and capricious. Additionally, the court found that the Registry did not abuse its discretion by not considering whether his Oregon conviction was a misdemeanor or felony. Lastly, the court concluded that the Registry was not required to compare Skehan’s Oregon conviction to Idaho offenses that do not require registration.The Registry was awarded its reasonable attorney fees pursuant to Idaho Code section 12-117. View "Skehan v. ISP" on Justia Law

In this case, Tyler Reece Rambo was convicted on three counts of aggravated assault upon a peace officer following an incident with police at a city park in Idaho. Rambo appealed his conviction, challenging several of the district court’s evidentiary rulings concerning the admission of evidence at his trial. Rambo argued that the court erred in excluding evidence of a civil lawsuit against the Coeur d’Alene Police Department, admitting body camera footage of his gun discharging, excluding body camera footage of officers returning fire, prohibiting him from testifying about the trajectory of a bullet, and prohibiting him from showing the jury his bullet scars. The Supreme Court of the State of Idaho affirmed the majority of the district court’s rulings and determined that the district court's one erroneous relevancy determination regarding the exclusion of body cam footage indicating that Rambo’s gun did not discharge a second time, was harmless. Therefore, the Supreme Court affirmed Rambo’s judgment of conviction. View "State v. Rambo" on Justia Law