Justia Idaho Supreme Court Opinion Summaries

The State appealed the district court’s order granting James Kent’s motion to suppress statements he made during a non-custodial interrogation. During this interrogation, the officer began reading Kent his Miranda rights, at which point Kent interrupted the officer and told him he would not answer any questions. The officer continued to read Kent his rights and, after completing the warnings, asked Kent if he was willing to speak with him. Kent said that he would, and eventually made incriminating statements. The district court suppressed the statements. The district court found that Kent was not in custody at the time, but nevertheless held: “Where Miranda warnings are read to an individual unnecessarily and the defendant invokes the right to remain silent, an officer may not ignore that invocation.” The State argued the district court erred by extending Miranda’s application to a non-custodial interrogation. In response, Kent contended that because he had a constitutional right to remain silent regardless of whether he was afforded Miranda warnings and irrespective of whether he was in custody, the district court did not err in suppressing his statements as having been obtained in violation of his right to remain silent. The Idaho Supreme Court determined the Kent made his statements voluntarily, therefore, the district court erred in suppressing the statements. Judgment was reversed and the matter remanded for further proceedings. View "Idaho v. Kent" on Justia Law

A group of prisoners (“Petitioners”) sought a writ of habeas corpus based on the conditions of their confinement during the COVID-19 pandemic. The Petitioners were all incarcerated at the Elmore County Jail (“Jail”), contending the conditions of confinement constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. More specifically, the Petitioners claimed they were in imminent danger because officials at the Jail did not implement any discernable mitigation measures in response to the COVID-19 pandemic. Elmore County Sheriff Mike Hollinshead and Lieutenant Shauna Gavin (collectively “Officials”) denied this assertion, contending that Petitioners’ request for a writ of habeas corpus should have been denied because the Petitioners did not exhaust their administrative remedies. The Officials filed a motion for summary judgment with the district court, which was granted. The district court also awarded the Officials their attorney fees. Petitioners timely appealed the district court’s decisions to the Idaho Supreme Court, which agreed to hear the appeal on an expedited basis. After that review, the Supreme Court affirmed the district court’s decision granting summary judgment, but reversed the district court’s award of attorney fees. View "Williams v. Hollinshead" on Justia Law

John Doe was a minor at the time the State alleged he committed two counts of lewd and lascivious conduct against a minor under the age of sixteen. Doe maintained his innocence, but argued that even if he did commit the acts alleged, the petition was time-barred under the four-year, catch-all limitation for civil actions found in Idaho Code section 5-224. The magistrate court (“juvenile court”) denied Doe's motion to dismiss the petition as untimely, and thereafter granted the State’s motion to waive Doe into adult proceedings. On intermediate appeal, the district court affirmed the decision of the juvenile court. The issue presented for the Idaho Supreme Court's review was whether proceedings under the Juvenile Corrections Act ("JCA") were "civil actions" subject to a civil statute of limitations. The Court concluded they were not, and affirmed the juvenile court, finding at JCA petition was not subject to the limitation in Idaho Code 5-224. View "Idaho v. Doe" on Justia Law

Appellant Derrick Lingnaw, a registered sex offender, sought declaratory relief from the district court asking whether he could legally reside on his property. The district court found Lingnaw’s residence was within five hundred feet of property on which a school was located, as that term was used in Idaho Code section 18-8329(1)(d). The court thus denied Lingnaw’s request to enjoin the Custer County Sheriff, Stuart Lumpkin, from interfering with Lingnaw’s ability to reside on his property. The court also denied Sheriff Lumpkin’s request for attorney fees and costs. On appeal, the parties mainly disputed the district court’s finding that Lingnaw’s residence was within five hundred feet of a school. After review, the Idaho Supreme Court affirmed the district court's ruling that Lingnaw's property was within five hundred feet of property on which a school was located. Lingnaw raised a question of fact as to whether the building, ruled as a "school," was simply a gymnasium and building leased by the Bureau of Land Management (“BLM”); Lingnaw argued the plain meaning of “school” required some form of traditional educational instruction. The trial court found “that the gymnasium, as contemplated by the statute, is a school building utilized by the school for school functions on a regular basis . . . for sporting events and other school activities. And children are coming and going from that building on a regular basis.” Because it was “clear from the evidence” that Lingnaw’s property fell “well within” five hundred feet or the buildings’ property line, the district court found that Lingnaw lived within five hundred feet of a school. To this, the Supreme Court concurred. The district court's judgment was affirmed in all other respects. View "Lingnaw v. Lumpkin" on Justia Law

Justin Loera was convicted for battery on a correctional officer. Loera claimed the district court erred in three respects: (1) by partially quashing his subpoena duces tecum based on its relevance rather than the standards prescribed in Idaho Criminal Rule 17(b); (2) for ordering restitution without sufficient evidence; and (3) by failing to address his request for credit for time served. After review of the facts specific to this case, the Idaho Supreme Court affirmed the district court’s decision to partially quash Loera’s subpoena duces tecum. However, the Court vacated the district court’s order awarding restitution and remanded the case with instructions for the court to award Loera 202 days of credit for time served. View "Idaho v. Loera" on Justia Law

Brandon Lynn Winkler appealed a district court order denying his motion to dismiss a January 2019 felony charge for driving under the influence of alcohol. Despite Winkler having been pardoned for a 2006 felony DUI, the district court determined that it still counted as a prior felony DUI for purposes of charging Winkler with a felony under Idaho Code section 18-8005(9). On appeal, Winkler argued the district court erred in concluding that a pardon did not prevent a prior felony DUI from being used to enhance a subsequent DUI charge to a felony under Idaho Code section 18-8005(9). The Idaho Supreme Court concurred: the district court erred in allowing Winkler's prior DUI conviction to be used to enhance his pending DUI charge. As such, the order was reversed and the matter remanded for further proceedings. View "Idaho v. Winkler" on Justia Law

Law enforcement used confidential informants to make several purchases of controlled substances from Darius Haws and his brother between April and May of 2015. While out on bond, Haws went to the residence of a female acquaintance. The woman called the police to report that Haws was trespassing. As a responding law enforcement officer approached Haws, the officer could “smell a strong odor of alcohol coming from [Haws’] breath.” When the officer attempted to arrest Haws, Haws resisted, swinging his arm and hitting the officer. Based on this altercation, the State charged Haws with battery on a police officer, resisting and obstructing an officer, criminal trespass, and disturbing the peace. Haws’ guilty pleas were entered pursuant to plea agreements in which he waived his right to appeal his convictions or sentences. The district court sentenced Haws to two years fixed, with four years indeterminate, for the delivery charge; and one year fixed, with three years indeterminate, for the battery charge. The sentences were ordered to run consecutively. Initially, the district court retained jurisdiction over Haws, but after performing poorly during the period of retained jurisdiction, the district court relinquished jurisdiction and ordered the original sentences be served. On appeal, Haws argued the district court abused its discretion in relinquishing jurisdiction and that his sentences were excessive. In response, the State sought to have Haws’ appeal dismissed because Haws expressly waived his right to appeal his sentences in the plea agreements he signed. The Court of Appeals agreed, dismissing Haws’ challenge to his sentences and affirming the district court’s decision to relinquish jurisdiction over Haws. On appeal to the Idaho Supreme Court, Haws contended the Court of Appeals incorrectly held that he had forfeited the right to address the validity of his plea agreements by not raising an issue of validity of those waivers in his opening brief. Instead, Haws contended it was the State’s obligation to assert the applicability of the appellate waiver, and that he should have had the opportunity to respond in his reply brief. Additionally, Haws argued his appellate waiver was not made knowingly, intelligently, and voluntarily because the district court made a statement that conflicted with the written plea agreements by noting that Haws had the right to appeal his sentences. The Supreme Court found no reversible error and affirmed the district and appellate courts. View "Idaho v. Haws" on Justia Law

Cari Oxford was convicted by jury of second degree kidnapping after she kidnapped her neighbor’s infant son. On appeal, Oxford contended the district court abused its discretion in: (1) denying her the funds necessary to retain an expert witness to assist with her defense; (2) refusing to allow the doctor who examined her for purposes of her competency evaluation to testify at trial regarding her mental health condition; and (3) ordering restitution without any evidence supporting it. Finding no reversible error as to her conviction, the Idaho Supreme Court affirmed. However, the restitution order was not supported by substantial evidence, so that order was vacated. View "Idaho v. Oxford" on Justia Law

Darius Haws appealed after he pled guilty to delivery of a controlled substance and battery on a police officer pursuant to plea agreements in which he waived his right to appeal his convictions or sentences. The district court sentenced Haws to two years fixed, with four years indeterminate, for the delivery charge; and one year fixed, with three years indeterminate, for the battery charge. The sentences were ordered to run consecutively. Additionally, the district court retained jurisdiction over Haws. However, after Haws performed poorly during the period of retained jurisdiction, the district court relinquished jurisdiction over Haws and ordered that the original sentences be served by Haws. Haws appealed, arguing that the district court abused its discretion in relinquishing jurisdiction and that his sentences were excessive. In response, the State sought to have Haws’ appeal dismissed because Haws expressly waived his right to appeal his sentences in the plea agreements he signed. The Court of Appeals dismissed Haws' challenge to his sentences and affirmed the district court's decision to relinquish jurisdiction. Haws appealed to the Idaho Supreme Court, arguing the appellate court erred in finding he forfeited his right to address the validity of his plea agreements. Haws contended that it was the State’s obligation to assert the applicability of the appellate waiver, and that he should have had the opportunity to respond in his reply brief. Additionally, Haws contended his appellate waiver was not made knowingly, intelligently, and voluntarily because the district court made a statement that conflicted with the written plea agreements by noting that Haws had the right to appeal his sentences. Finding no reversible error in the appellate's or trial court's decisions, the Supreme Court affirmed. View "Idaho v. Haws" on Justia Law

In December 2017, Klaus Nico Gomez-Alas was charged with two felony counts: rape and infamous crime against nature. At trial, he was acquitted of rape, but convicted of simple battery as an included offense. On the second count, the jury found Gomez-Alas guilty of an infamous crime against nature. After the verdict, Gomez-Alas moved the district court for a new trial pursuant to Idaho Criminal Rule (I.C.R.) 34, arguing the district court misled the jury by giving an improper “dynamite” instruction. Gomez-Alas also moved the district court for judgment of acquittal on the second count pursuant to I.C.R. 29, arguing there was insufficient evidence to support a conviction for the infamous crime against nature charge. The district court denied both post-trial motions. Gomez-Alas argued on appeal to the Idaho Supreme Court: (1) the act of cunnilingus does not constitute an infamous crime against nature under Idaho Code sections 18-6605 and 18-6606; (2) there was insufficient evidence to support a conviction for the infamous crime against nature charge; and (3) the district court misled the jury by providing an improper dynamite instruction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Gomez-Alas" on Justia Law