Justia Idaho Supreme Court Opinion Summaries

Adrian Renee Soliz was found unconscious behind the wheel of his vehicle, which was impeding traffic. Concerned, a passerby called 9-1-1, and emergency responders arrived at the scene. They discovered drug paraphernalia on Soliz's lap while providing medical assistance for what was later confirmed to be a drug overdose. Soliz was subsequently charged with possession of a controlled substance, possession of drug paraphernalia, and other related offenses.Soliz filed a motion to dismiss the charges, arguing that under Idaho’s overdose immunity statute (Idaho Code section 37-2739C(2)), he should be immune from prosecution because the evidence was obtained as a result of his medical emergency. The State opposed the motion, contending that the evidence was discovered during a traffic investigation, not solely due to the medical emergency. The district court denied Soliz’s motion, concluding that the evidence was not obtained solely as a result of the medical emergency.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The Court held that the phrase “as a result of” in the overdose immunity statute means that the drug-related medical emergency must be the sole cause of the discovery of evidence. Since the evidence was discovered during both a traffic investigation and a medical emergency response, the statute did not apply. Therefore, Soliz was not entitled to immunity, and the district court’s denial of his motion to dismiss was upheld. View "State v. Soliz" on Justia Law

John David Wurdemann was charged and convicted of seven felonies related to a 2000 attack on a woman in Canyon County, Idaho. Sixteen years later, a district court granted his petition for post-conviction relief, vacating his convictions due to ineffective assistance of counsel. This decision was affirmed by the Idaho Supreme Court in 2017. Wurdemann has not been retried since.Wurdemann filed a petition under the Idaho Wrongful Conviction Act, seeking compensation and a certificate of innocence. The State opposed the petition and moved for summary judgment, which the district court granted. The district court concluded that Wurdemann had not established that the basis for vacating his conviction was not legal error unrelated to his factual innocence, as required by the Act.The Idaho Supreme Court reviewed the case and interpreted the statutory language of the Idaho Wrongful Conviction Act. The Court held that the phrase “not legal error unrelated to his factual innocence” means “legal error related to his factual innocence.” The Court concluded that the ineffective assistance of counsel claim, which led to the reversal of Wurdemann’s convictions, did not establish his factual innocence. The reversal was based on the improper admission of lineup evidence, not on evidence showing Wurdemann was actually innocent. Therefore, Wurdemann could not satisfy the statutory requirement, and the district court's grant of summary judgment to the State was affirmed. View "Wurdemann v. State" on Justia Law

In this case, the appellant, Chitta Roy, challenged the Idaho Department of Health and Welfare's (the "Department") denial of her criminal history background clearance during her certified family home (CFH) recertification. Roy had a 2008 conviction for involuntary manslaughter, which was dismissed in 2011 under Idaho Code section 19-2604 after she successfully completed probation. Despite this, the Department denied her 2021 application for background clearance, citing the conviction as a disqualifying crime under its updated rules.The District Court of the Seventh Judicial District of Idaho upheld the Department's decision, rejecting Roy's arguments that the dismissal of her conviction should preclude the Department from denying her clearance and that the Department should be bound by its 2009 decision to grant her an exemption. The district court also determined that Roy failed to show substantial prejudice from the denial, as the Department could still approve her CFH recertification through a separate process.The Supreme Court of Idaho reviewed the case and found that the district court erred in its conclusions. The Supreme Court held that the Department improperly based its denial on the dismissed conviction, which, under Idaho Code section 19-2604, should be treated as if it never existed. The Court also determined that the case was ripe for adjudication and that Roy's substantial rights were prejudiced by the Department's denial. The Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. Roy was awarded costs on appeal. View "Roy v. Idaho Department of Health and Welfare" on Justia Law

John David Wurdemann was convicted of seven felonies related to a 2000 attack on a woman in Canyon County, Idaho. Sixteen years later, a district court granted his petition for post-conviction relief, vacating his convictions due to ineffective assistance of counsel. This decision was affirmed by the Idaho Supreme Court in 2017. Wurdemann was not retried. In 2021, Idaho enacted the Idaho Wrongful Conviction Act, which allows for compensation for wrongfully convicted individuals who meet specific criteria. Wurdemann filed a petition under this Act seeking compensation and a certificate of innocence.The district court granted the State's motion for summary judgment, concluding that Wurdemann had not established that the basis for vacating his conviction was not legal error unrelated to his factual innocence, as required by the Act. Wurdemann appealed this decision.The Idaho Supreme Court reviewed the case and interpreted the statutory language of the Idaho Wrongful Conviction Act. The Court held that the phrase “not legal error unrelated to his factual innocence” means “legal error related to his factual innocence.” The Court concluded that the legal error in Wurdemann’s case—ineffective assistance of counsel due to failure to challenge a suggestive police lineup—did not establish his factual innocence. The reversal of his convictions was based on the deficient performance of his trial attorneys, not on evidence proving his innocence. Therefore, Wurdemann did not meet the statutory requirement for compensation under the Act.The Idaho Supreme Court affirmed the district court’s grant of summary judgment in favor of the State, concluding that Wurdemann could not satisfy the necessary element of showing that the basis for reversing his conviction was related to his factual innocence. View "Wurdemann v. State" on Justia Law

While employed as a bookkeeper for Castlerock Homes, Sarah Brizzee embezzled over $230,000 by writing fraudulent checks and using the company credit card for personal purchases. She also created fraudulent lien waivers and invoices to cover her tracks. The crimes were discovered in October 2018, and Brizzee was charged with grand theft and forgery in April 2019. She pleaded guilty to one count of each and was sentenced in March 2020 to a unified sentence of seven years, with two years determinate and five years indeterminate, but the court retained jurisdiction, placing her on a rider program. She was released from incarceration in October 2020 and placed on probation until October 2026.The District Court of the Seventh Judicial District of Idaho found that Idaho Code section 5-248 created a one-year statute of limitations for crime victims to file civil claims, starting from the offender's release from incarceration. Since Brizzee was released from her rider in October 2020, the court ruled that Castlerock's complaint, filed in September 2022, was untimely and dismissed the case with prejudice.The Supreme Court of Idaho reviewed the case and held that Idaho Code section 5-248 does not create a one-year limitations period but instead tolls the applicable limitations period until one year after the offender has been released from incarceration and has fully satisfied the sentence imposed. The court found that the district court erred in dismissing Castlerock’s complaint as untimely. The Supreme Court vacated the judgment and remanded the case for further proceedings, clarifying that the statute of limitations was tolled during Brizzee's incarceration and for one year after her release, making Castlerock's complaint timely. View "JK Homes, LLC v. Brizzee" on Justia Law

Jakobe G. Martin was charged with three counts of statutory rape involving a 17-year-old female, K.F., who reported that Martin had raped her on three occasions. Martin allowed K.F., a runaway, to stay at his apartment, where she later accused him of both forced and consensual sexual intercourse. During the investigation, DNA evidence was collected, and K.F. made statements during a forensic interview that conflicted with the DNA results.The District Court of the Fourth Judicial District of Idaho heard the case. The State filed a motion in limine under Idaho Rule of Evidence 412 to exclude evidence of the victim’s sexual history. Martin argued that he should be allowed to use certain evidence for impeachment purposes, specifically to challenge a statement K.F. made during her forensic interview. The district court allowed Martin to inquire about the DNA results but barred the use of the victim’s statements about her sexual history for impeachment, citing Rule 412(b). Martin was convicted of one count of rape and sentenced to a twenty-year term, with seven years fixed and thirteen years indeterminate.The Supreme Court of Idaho reviewed the case. The court held that the evidence Martin sought to introduce was properly excluded under Rule 412(b), which prohibits evidence of an alleged victim’s past sexual behavior unless it falls within specific exceptions. The court also noted that Martin failed to provide the required notice under Rule 412(c). Consequently, the Supreme Court affirmed Martin’s judgment of conviction. View "State v. Martin" on Justia Law

Desiree Elaine Karst was a passenger in a car stopped by police in Kootenai County, Idaho. During the stop, a drug dog alerted to the presence of drugs, and Karst admitted to having drugs in the car. Additional drugs and paraphernalia were found on her at the jail. She was charged with multiple drug offenses and introducing contraband into a correctional facility. Karst moved to suppress the evidence, arguing the stop was impermissibly extended. The district court partially denied her motion, and Karst entered conditional guilty pleas, reserving her right to appeal. She was ordered to pay $569.50 in various court fees.Karst appealed the partial denial of her motion to suppress. The Idaho Supreme Court found the traffic stop was impermissibly extended, reversed the district court’s decision, and remanded the case. Subsequently, the prosecutor dismissed all charges against Karst. Karst then filed a motion to reimburse the fees she had paid, arguing that retaining her funds violated her due process rights. The district court denied her motion, citing a lack of jurisdiction and suggesting she sue each governmental entity that received the fees.The Idaho Supreme Court reviewed the case and held that the district court had both personal and subject matter jurisdiction to consider Karst’s motion for reimbursement. The court found that the State, by initiating the criminal case, had submitted to the district court’s jurisdiction. The court also determined that requiring Karst to file multiple civil suits to recover the fees would impose more than minimal procedures, violating her due process rights. The court reversed the district court’s decision and remanded the case for further proceedings, instructing that Karst should be reimbursed if she proves she paid the fees and her conviction was invalidated. View "State v. Karst" on Justia Law

In 1988, Rodney Araiza was involved in a riot at the Idaho State Penitentiary, during which an inmate named Richard Holmes was murdered. Araiza was charged with first-degree murder and participating in the riot. At trial, the State presented evidence, including testimonies and Araiza’s bloody palm prints, suggesting Araiza's involvement in the murder. Araiza defended himself by claiming he arrived at Holmes' cell after the murder. Despite his defense, Araiza was convicted by a jury on both charges in 1989.After his conviction, Araiza filed a motion for a new trial, presenting new evidence, including a confession from another inmate, Merle LaMere, who claimed responsibility for the murder. However, the district court denied the motion, finding the new evidence unlikely to result in an acquittal. Araiza was sentenced to life imprisonment for murder and 20 years for riot, to be served concurrently. Araiza's subsequent appeals, including a direct appeal, were unsuccessful.In 2019, Araiza filed a petition for post-conviction relief, claiming actual innocence and requesting DNA and fingerprint testing. The district court dismissed the petition, stating that the DNA evidence would not likely prove Araiza's innocence and that his claims were barred by res judicata. Araiza did not receive notice of this dismissal until after the appeal period had expired. He then filed a motion for relief from judgment under Idaho Rules of Civil Procedure 60(b)(1) and 60(b)(6), which led to the district court reentering judgment.Araiza appealed the reentered judgment, but the Idaho Court of Appeals dismissed the appeal as untimely. The Supreme Court of Idaho reviewed the case and concluded that Araiza's appeal was indeed untimely, as his motion for relief from judgment was filed outside the six-month limit for Rule 60(b)(1) motions. Consequently, the Supreme Court dismissed Araiza’s appeal for lack of jurisdiction. View "Araiza v. State" on Justia Law

In 2018, Brian Hollis pleaded guilty to one count of lewd conduct with a minor under sixteen and four counts of sexual exploitation of a child. He also admitted to being a repeat sexual offender, which mandates a fifteen-year minimum term of confinement. The district court imposed an indeterminate life sentence with twenty-five years determinate on the lewd conduct charge and concurrent determinate sentences of fifteen years for each of the sexual exploitation charges. Hollis appealed his conviction and sentence, but the Idaho Court of Appeals affirmed them.Hollis then filed a pro se petition for post-conviction relief, alleging ineffective assistance of trial counsel. The district court appointed the Kootenai County Public Defender to represent him. However, Hollis' conflict counsel filed a motion to withdraw, stating that he was no longer able to "ethically or effectively represent" Hollis due to statements made by the district court judge against conflict counsel in a similar post-conviction case. The district court denied the motion to withdraw and the motion to continue the summary disposition hearing. The district court subsequently granted the State’s motion for summary disposition, holding that Hollis had not supported any of his claims with any admissible evidence.The Supreme Court of the State of Idaho vacated the judgment of the district court, reversed the decisions on the motion to continue and motion to withdraw, vacated the decision granting summary disposition to the State, and remanded for further proceedings. The court held that the district court abused its discretion in denying the motion to withdraw and the motion to continue. The court also ordered the assignment of a new district court judge on remand. View "Hollis v. State" on Justia Law

The case revolves around John Thomas Bujak, who pleaded guilty to grand theft and was placed on probation with the condition of serving thirty days in jail. Bujak scheduled his jail time on weekends to maintain his employment during the week. After serving his first jail stay from Friday morning to Sunday morning, Bujak learned that he would receive credit for two days of jail time. He then moved the district court for credit for time served, arguing that he should receive three days credit because he served time over the course of three calendar days.The district court denied Bujak’s motion, interpreting that the terms of its probation order required Bujak to serve thirty, twenty-four-hour periods in jail. Bujak appealed this decision, arguing that Idaho Code section 18-309 required the district court to award him one day of credit for each partial day of jail time he served.The Supreme Court of the State of Idaho affirmed the district court’s order. The court concluded that neither section 18-309 nor section 19-2603 applies to the calculation of Bujak’s time served. Instead, the court found that Idaho Code section 19-2601(3) controls, which allows a district court to withhold judgment and impose probation terms it deems necessary and appropriate. The court agreed with the district court's interpretation that Bujak was required to serve thirty, twenty-four-hour days in jail as a term of his probation. View "State v. Bujak" on Justia Law