Justia Idaho Supreme Court Opinion Summaries

In 2006, Timothy Dunlap was sentenced to death by a Caribou County, Idaho jury for the death of a Soda Springs bank teller killed in 1991. In 2008, Dunlap filed a petition for post-conviction relief, alleging that numerous errors had occurred at his 2006 sentencing hearing. The district court dismissed the petition in its entirety. Dunlap appealed to the Supreme Court, which affirmed the dismissal of all but two of Dunlap’s claims: (1) multiple claims of prosecutorial misconduct under Brady v. Maryland, 373 U.S. 83 (1963) and Napue v. Illinois, 360 U.S. 264 (1959); and (2) ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984). Upon remand, the district court held two evidentiary hearings, one involving each of Dunlap’s remaining claims. The district court found that Dunlap had failed to establish either claim and denied Dunlap’s request for post-conviction relief. Dunlap timely appealed. Finding no reversible error in these decisions, the Idaho Supreme Court affirmed the district court. View "Dunlap v. Idaho" on Justia Law

Adam Paulson was arrested for misdemeanor driving under the influence (DUI) at the scene of the accident; he struck and killed a pedestrian with his vehicle as the pedestrian was crossing a road on a late November 2017 night. He was later charged with vehicular manslaughter, and a jury trial was held in October and November 2018. The jury convicted Paulson of vehicular manslaughter. Paulson appealed his conviction, arguing the district court erred when it refused to instruct the jury on the causation element required by Idaho Code section 18- 4006(3)(b). Paulson argued the district court should have instructed the jury regarding proximate, intervening, and superseding causes because the pedestrian, who was intoxicated, crossed the road in an unlit area with no marked crosswalk. Paulson also contended his right to a fair trial was violated when the district court instructed the jury using Idaho Criminal Jury Instruction (ICJI) 709, arguing that ICJI 709 did not set forth all the elements of Idaho Code section 18-4006(3)(b). After review, the Idaho Supreme Court found the district court erred in declining to instruct the jury on the required causal link between a defendant’s unlawful conduct and the victim’s death. The Court also found the district court erred in refusing to instruct the jury on whether the pedestrian’s conduct constituted an intervening, superseding cause and on a pedestrian’s duties when walking along roadways. The Supreme Court vacated Paulson's vehicular manslaughter conviction; the case was remanded for further proceedings. View "Idaho v. Paulson" on Justia Law

Defendant-appellant Corey McGrath was charged with two counts of lewd conduct with a minor: one regarding his five-year-old stepdaughter, B.B.; and one regarding his twelve-year-old stepdaughter, L.N. The two counts were severed for trial. During a jury trial on the first count, and over McGrath’s objection, the State introduced evidence of McGrath’s cell phone internet search history, which included searches for stepfather-stepdaughter themed pornography, along with two still images of pornographic videos purportedly viewed by McGrath. The jury convicted McGrath of one count of lewd conduct with respect to B.B. McGrath subsequently, pursuant to a plea agreement, pleaded guilty to felony injury to a child regarding L.N.’s accusations in the second count. McGrath was sentenced to life in prison with twenty years fixed for the lewd conduct charge, and ten years fixed for the felony injury to a child charge. The sentences were ordered to run concurrently. McGrath appealed his conviction of lewd conduct and the sentences imposed for both convictions. The Idaho Court of Appeals affirmed McGrath’s convictions and sentences. Finding no reversible error, the Idaho Supreme Court likewise affirmed McGrath's convictions and sentences. View "Idaho v. McGrath" on Justia Law

Defendant-appellant Danielle Guerra appealed a district court’s decision affirming a judgment of conviction for driving under the influence of drugs (“DUI”). Guerra contended the magistrate court erred when it denied her motion to set aside the jury verdict under Idaho Criminal Rule 29 or, in the alternative, grant a new trial under Idaho Criminal Rule 34. Further, Guerra argued the magistrate court erred when making a number of evidentiary rulings. The district court, acting in its appellate capacity, affirmed the magistrate court’s rulings and judgment of conviction. The Idaho Supreme Court found the district court erred when it upheld the magistrate court’s ruling permitting the arresting officer to testify about the motor vehicle warning on Guerra’s medication bottles. The pill bottles found in Guerra’s car were not offered or admitted into evidence. The officer testified to three warnings or “signs” on the medication bottles. The Court found that the inclusion of a warning on a medication bottle to “take due caution when operating a motor vehicle or heavy equipment” was more than just an admonishment: "The warning impliedly asserts that the medication in the bottle may impair the user’s ability to drive a car or use heavy equipment. Because this warning constitutes an assertion of fact that is capable of being proven true (i.e., the medication may impair the ability to drive), Officer DeLeon’s testimony concerning that warning constituted an assertion of fact and is subject to the hearsay rules." The Supreme Court concluded the State failed to carry its burden of demonstrating a proper non-hearsay purpose for the motor vehicle warning evidence. "The harmfulness of allowing Officer DeLeon’s testimony about the warning to come in for the truth of the matter asserted is evidenced in the statements of multiple jurors during voir dire in response to the prosecutor’s questions related to taking prescription medications while driving." Judgment was affirmed in part, reversed in part, and remanded the case to the district court with instructions to vacate the judgment of conviction and remand the case to the magistrate court for further proceedings. View "Idaho v. Guerra" on Justia Law

A grand jury indicted defendant-appellant Jordan Spencer for three counts of felony trafficking in heroin, one count of felony possession of methamphetamine, one count of felony possession of bath salts with intent to deliver, and one count of misdemeanor possession of drug paraphernalia. After a jury trial, Spencer was found guilty on all counts. Spencer appealed two of the six counts of which he was convicted, arguing there was insufficient evidence to sustain his conviction on one count of trafficking in heroin, and that the district court erred when it admitted the out-of-court statements of the State’s confidential informant because those statements violated his Sixth Amendment right to confront witnesses. The Idaho Supreme Court vacated Spencer's conviction on Count I, finding it was not supported by substantial evidence on which the jury could conclude the prosecution proved all essential elements beyond a reasonable doubt. The Court affirmed Spencer’s conviction of trafficking heroin as charged in Count II. View "Idaho v. Spencer" on Justia Law

Defendant-appellant was convicted by jury of domestic battery, attempted strangulation, and aggravated assault. He appealed to the Idaho Court of Appeals, which affirmed his convictions. Reyes petitioned for review by the Idaho Supreme Court, which was granted. On appeal, Reyes requested his convictions be vacated, arguing: (1) several evidentiary issues, including the admission of irrelevant and prejudicial evidence, rendered his trial unfair; (2) the district court abused its discretion when it found that the victim was unavailable to testify at trial under Idaho Rule of Evidence 804(a)(5) and allowed her preliminary hearing testimony to be read into the record; (3) the prosecutor’s closing argument impermissibly implied that the victim did not testify because she feared Reyes; and (4) these errors, when taken together, deprived him of his right to due process and a fair trial. After review, the Supreme Court found the district court erred when it determined the victim was unavailable to testify at trial, and allowed her preliminary hearing testimony to be read into the record. Further, the Court concurred the prosecutor's comment that the victim was "probably scared" to testify at trial was improper. In the aggregate, the Court concluded these errors rendered the trial unfair. Accordingly, Reyes' conviction was reversed and the case remanded for a new trial. View "Idaho v. Reyes" on Justia Law

A drug dog leapt into defendant-appellant Jacob Randall’s rental car during what was supposed to have been an exterior sniff. After the dog alerted to the presence of narcotics, officers searched the car and discovered 65 pounds of marijuana. Relying on an Idaho Court of Appeals case providing that a drug dog’s “instinctive” actions did not violate the Fourth Amendment, the district court denied Randall’s motion to suppress evidence of the marijuana because it found the dog’s entry was instinctive. The Idaho Supreme Court reversed, finding the rule articulated by the Court of Appeals and applied by the district court was inconsistent with the Fourth Amendment. View "Idaho v. Randall" on Justia Law

In March 2019, police officers stopped defendant-appellant Aaron Howard for a traffic violation and took him into custody after discovering an outstanding warrant for his arrest. Officers then brought in a drug-sniffing dog (“Pico”) to sniff the exterior of the car. Pico alerted to the presence of illegal drugs, and a subsequent search of the care uncovered methamphetamine, heroin and drug paraphernalia. Howard appealed the denial his motion to suppress the drug evidence, arguing the intrusion of the dog into the physical space of the car was a trespass, and therefore, an unlawful search under the common law trespassory test articulated in United States v. Jones, 565 U.S. 400 (2012). The Idaho Supreme Court agreed, reversed the denial of Howard’s motion to suppress, vacated his conviction, and remanded this case for further proceedings. View "Idaho v. Howard" on Justia Law

In December 2018, a Jack-in-the-Box employee suspected a “drunk driver” was in the restaurant’s drive-through line and reported this suspicion to law enforcement. An officer arrived on the scene and reported an odor of alcohol emanating from the passenger side of the vehicle, as well as empty alcohol containers on the floor near the vehicle’s passenger. The officer directed the driver, later identified as Andrew Wilson, to park the car. Wilson exited the vehicle. After noticing the odor of alcohol coming from Wilson, the officer began conducting field sobriety tests. The officer interpreted Wilson’s results as presenting signs of impairment. The officer then arrested Wilson for driving under the influence (DUI). A warrant for a blood draw was ultimately obtained after Wilson refused to submit to a breath test. The result of the blood draw conducted at the Pocatello Police Department reported a blood alcohol content of 0.192 percent. Wilson was charged with felony DUI based on two prior DUI convictions within the previous ten years. Wilson moved to suppress all evidence obtained as a result of his initial detention, arguing that the officer did not have reasonable suspicion to detain him in the restaurant parking lot. The district court granted Wilson’s motion and dismissed the charge against him with prejudice. The State appealed this decision to the Idaho Court of Appeals, which reversed the district court. The Idaho Supreme Court granted Wilson’s petition for review, and affirmed the district court’s decision to suppress because the State failed to preserve its argument for appeal. The Supreme Court found the State did not submit a responsive motion to Wilson's motion at the suppression hearing. "Allowing the State to argue on appeal that Officer Malone developed reasonable suspicion to detain Wilson prior to Wilson’s exit from the vehicle, when it implicitly conceded this point below, 'would sharply cut against our longstanding and recently re-affirmed policy of requiring parties to present their arguments to the court below[.]'" View "Idaho v. Wilson" on Justia Law

The State appealed a district court’s order granting Jennifer Warren’s (“Jennifer”) motion to suppress evidence. Boise Police Department Officer Matthew Lane stopped a GMC Yukon for a canceled and expired registration. The vehicle was driven by Steven Warren (“Steven”), and Jennifer was in the passenger seat. Steven told officers that Jennifer was his wife. Lane ran the identification information supplied by both parties, and the data system alerted there was a civil protection order and a criminal no-contact order in place preventing Steven from having contact with Jennifer. At this point, the officer abandoned the original purpose of the traffic stop in order to investigate whether Steven was in violation of either order by being with Jennifer in the car. To separate Jennifer from Steven, a second officer, Andrew Morlock, asked Jennifer to step out of the vehicle. Morlock asked Jennifer about some bulges in her pockets, and she pulled out a lighter, some money, and two syringes wrapped in tissue. Lane ran his drug-detection dog around the vehicle, and the dog alerted. A search of the car turned up a suspected marijuana joint and a tin holding small containers of a waxy substance, one of which later tested presumptively positive for marijuana. Jennifer’s purse was also in the vehicle and contained pills later identified as hydrocodone. During the car search, dispatch confirmed that the criminal no-contact order against Steven was active. Steven was taken into custody; Jennifer was arrested for possession of drug paraphernalia, and a subsequent search of her person revealed another syringe and a baggie of methamphetamine hidden in her bra. The State charged Jennifer with possession of methamphetamine, possession of hydrocodone, possession of marijuana, and possession of drug paraphernalia, as well as a persistent violator enhancement. The district court concluded the officers had no lawful basis to continue detaining Jennifer, a passenger in a vehicle, after officers abandoned the original purpose of the traffic stop in order to investigate whether the driver was in violation of a criminal no contact order barring him from being with Jennifer. On appeal, the State argued that reasonable suspicion a driver is engaged in criminal conduct not only allows officers to extend a traffic stop and detain the driver, but it also includes the continued lawful detention of all passengers. To this, the Idaho Supreme Court concurred and reversed the district court's suppression order. View "Idaho v. Warren" on Justia Law