Justia Idaho Supreme Court Opinion Summaries

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

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

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

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

Defendant Max Gorringe appeaeled a district court’s order amending of a no contact order. A no contact order was originally entered against Gorringe after he was initially charged with attempted strangulation in 2011. Upon acceptance of Gorringe’s guilty plea to that charge in 2012, the district court rescinded the existing no contact order and in its place included no contact provisions in the Judgment and Commitment. In 2018, Gorringe was charged with a misdemeanor for allegedly violating the no contact provisions contained in the original Judgment and Commitment. Gorringe sought clarification of the existing provisions originally entered the judgment, then moved to modify the no contact provisions. The parties stipulated to an amendment of the order in exchange for the dismissal of Gorringe’s misdemeanor charge. Although the district court expressed reservations regarding its jurisdiction to amend the no contact provisions that had been incorporated into the prior Judgment and Commitment, the district court nonetheless amended the 2012 no contact order based on the parties’ stipulation and the State’s assurance that the victim did not object to the amendment. Gorringe appealed the district court’s order amending the no contact provisions, asserting that the no contact provisions included in the 2012 Judgment and Commitment were invalid. Gorringe also claimed the district court lacked subject matter jurisdiction to amend the order in 2018. The Idaho Supreme Court concluded the no contact provision in the district court's 2012 Judgment was unenforceable; the court lacked jurisdiction to amend the 2012 no contact order. The district court order amending the no contact order was thus reversed, and the provisions in the 2012 sentencing order were void. View "Idaho v. Gorringe" on Justia Law

The State charged Carli Campbell as an accessory to a felony under Idaho Code section 18-205(1) for withholding or concealing information from police officers about an aggravated battery and burglary that occurred in her home in December 2017. After the evidentiary phase of the trial was completed, Campbell requested the district court instruct the jury that the State was required to prove that the alleged assailant, Michael Cross, committed the aggravated battery or burglary beyond a reasonable doubt. The State opposed this request and the district court agreed, concluding that while the State was required to prove Campbell had knowledge of the conduct that constituted an aggravated battery or a burglary, it was not was required to prove Cross committed the aggravated battery or burglary beyond a reasonable doubt. At the conclusion of the trial, the jury found Campbell guilty. Campbell now appeals her conviction to this Court. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed. View "Idaho v. Campbell" on Justia Law

In 1985, Gerald Pizzuto Jr. murdered Berta and Delbert Herndon. Pizzuto was convicted of two counts of murder in the first degree, two counts of felony murder, one count of robbery, and one count of grand theft. He was sentenced to death for the murders. Between 1986 and 2003, Pizzuto filed five petitions for post-conviction relief. His fifth petition for post-conviction relief was predicated on the holding in Atkins v. Virginia, 536 U.S. 304 (2002), in which the U.S. Supreme Court held that the execution of an intellectually disabled person constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. In his fifth petition, Pizzuto asserted that his death sentence should be “reversed and vacated” because he was intellectually disabled. The district court summarily dismissed Pizzuto’s petition. The Idaho Supreme Court held that the district court did not err when it dismissed Pizzuto’s fifth petition for post-conviction relief on the basis that Pizzuto had failed to raise a genuine issue of material fact supporting his claim that he was intellectually disabled at the time of the murders and prior to his eighteenth birthday. Pizzuto pursued this same claim in a federal habeas corpus action. In 2016, the U.S. District Court for the District of Idaho denied Pizzuto’s successive petition for writ of habeas corpus after holding a four-day evidentiary hearing in 2010. Although it affirmed the federal district court’s decision denying Pizzuto’s successive petition for writ of habeas corpus, the Ninth Circuit stated in dicta that its decision does not preclude Idaho courts from reconsidering whether Pizzuto was intellectually disabled at the time of the murders. Based on this dicta, Pizzuto filed a motion with the district court to alter or amend the judgment dismissing his fifth petition for post-conviction relief in accordance with Idaho Rule of Civil Procedure 60(b)(6). The district court denied Pizzuto’s Motion in early 2020. Because the district court did not abuse its discretion in denying Pizzuto’s Motion, the Idaho Supreme Court affirmed the district court’s decision. View "Pizzuto v. Idaho" on Justia Law

Daniel Chernobieff appealed a district court’s decision on intermediate appeal to uphold a magistrate court’s summary dismissal of his petition for post-conviction relief. Chernobieff was convicted of a misdemeanor for driving under the influence with an excessive blood alcohol content in June 2014. After the Idaho Supreme Court upheld his conviction on direct appeal, Chernobieff filed a petition for post-conviction relief on the basis of ineffective assistance of counsel. He alleged that his defense counsel’s decision to object to testimony at a suppression hearing suggesting that the on-call magistrate could not be reached to obtain a warrant because his cell phone ringer was off was unreasonable and prejudicial. He argued that the objection to the ringer testimony prevented him from arguing at trial that the State did not have good cause for the on-call magistrate's unavailability. The magistrate court granted the State's motion for summary dismissal, reasoning the objection was an unreviewable strategic decision and would not have changed the outcome of the case. The district court, sitting in an appellate capacity, affirmed. Finding no reversible error, the Supreme Court also affirmed. View "Chernobieff v. Idaho" on Justia Law

The State charged Keith Sarbacher with grand theft by receiving or possessing stolen property: a 2001 Dodge pickup truck. After Sarbacher’s arrest, the State inventoried and photographed the truck and then returned it to the insurance company, who then sold the truck before Sarbacher’s attorneys could examine it. Sarbacher moved the district court for dismissal, arguing that the State violated his constitutional right to due process by disposing of evidence that was material and potentially exculpatory. The district court granted Sarbacher’s motion and dismissed the State’s case. The State appealed, arguing the evidence at issue was of unknown exculpatory value and the trial court expressly found that the State had not acted in bad faith. The Idaho Supreme Court concluded after a review of the district court record, it would have been entirely speculative for the district court to conclude that any of the additional analyses Sarbacher wanted to conduct would have resulted in the discovery of any exculpatory evidence to exonerate him. "the evidentiary value of the truck as the corpus delicti of the crime was sufficiently preserved by the State through its inventorying and photographing the vehicle prior to its release to Hunt’s insurance company." The Court vacated the district court's decision and remanded for further proceedings. View "Idaho v. Sarbacher" on Justia Law

This case arose from a DUI suspect’s request to make a phone call from jail following his arrest. The State appealed a district court order granting Jeffery Stegall’s motion to suppress blood alcohol concentration (BAC) evidence obtained from a blood draw. The district court granted Stegall’s motion after determining that his right to due process had been violated when police officers at the jail refused his request to make a phone call. The State argued on appeal that the district court erred in determining Stegall’s due process rights were violated because the officers were not acting in bad faith when they failed to allow him access to a phone. To this, the Idaho Supreme Court disagreed, holding the district court did not err in determining the jail officers violated Stegall’s right to procedural due process when, despite his requests, they failed to allow him access to a phone for the purpose of contacting an attorney until the morning following his arrest. Accordingly, the district court’s order granting Stegall’s motion to suppress evidence of BAC was affirmed. View "Idaho v. Stegall" on Justia Law