Justia Idaho Supreme Court Opinion Summaries

Martin Edmo Ish was convicted of voluntary manslaughter in 2017 and sentenced to 15 years, with 10 years fixed and five years indeterminate. However, his original conviction was later vacated by the Idaho Supreme Court in 2020. After the court's decision became final, Ish's bail was reinstated. Unable to post a bond, he was returned to jail to await his retrial. His second trial was postponed several times due to public safety concerns during the COVID-19 pandemic. Ish repeatedly moved for dismissal of his case citing speedy trial concerns, but his requests were denied. He also moved for a change of venue, which was also denied. His second trial commenced in July 2021, and he was again convicted of voluntary manslaughter. This time, he was sentenced to a fifteen-year unified sentence, with the first 14 years fixed and one year indeterminate, resulting in a fixed sentence four years longer than his original sentence. Ish appealed his conviction and sentence.The Idaho Supreme Court affirmed Ish's judgment of conviction and sentence. The court found that Ish's right to a speedy trial was not violated, as the delays were either neutral or justifiable. The court also found that the district court did not err in denying Ish's motion for a change of venue, as Ish failed to demonstrate that the jury pool was tainted by media coverage. The court further found that Ish did not demonstrate that a juror should have been excused for bias. The court also found that the district court did not err in imposing an unduly harsh sentence, and that the court did not err in denying Ish's Rule 35 motion for leniency following his second sentence. View "State v. Ish" on Justia Law

Benny Dean Campbell was detained by law enforcement while they were investigating a stolen motorcycle. During the detention, a police trooper discovered heroin and methamphetamine in Campbell's backpack. Campbell was charged with two felony counts for drug trafficking and possession of a controlled substance, and two misdemeanor counts for possession of a controlled substance and possession of drug paraphernalia. Campbell filed a motion to suppress the evidence, arguing that by initially placing him in handcuffs, the trooper converted his detention into an unlawful seizure under the Fourth Amendment to the United States Constitution.The district court agreed that Campbell’s detention was a de facto arrest; however, the court also determined that the evidence was admissible under the attenuation doctrine. After the court denied his motion, Campbell entered into a conditional plea agreement that preserved his right to appeal the denied motion. On appeal, he asked the Supreme Court of the State of Idaho to reject the federal attenuation doctrine because Article I, section 17 of the Idaho Constitution affords him greater protections than the federal standard and is incompatible with Idaho’s more expansive exclusionary rule.The Supreme Court of the State of Idaho affirmed the order of the district court. The court agreed with the district court’s conclusion that the State failed to establish that the use of handcuffs on Campbell was a reasonable precaution for the trooper’s safety. However, the court concluded that while the seizure of Campbell was unreasonable, the inevitable discovery exception to the Fourth Amendment makes suppression improper. The court found that even if handcuffs had never been used, the evidence would have been inevitably discovered whether the trooper had followed either parallel path once the trooper walked into the convenience store. Therefore, the court affirmed the district court’s order denying Campbell’s suppression motion on the alternate theory of inevitable discovery. View "State v. Campbell" on Justia Law

Dale Carter Shackelford was found guilty on six counts, including two counts of first-degree murder, and was sentenced to death for the murder counts and to various terms for the other counts, all to be served concurrently. However, the death sentences were vacated due to a Supreme Court decision, and the case was remanded for resentencing. At the resentencing hearing, Shackelford was given fixed life sentences for the murder counts to be served consecutively, but the court did not address the other counts. The written judgment stated that the murder sentences were to run consecutively with each other and with the sentences for the other counts.Shackelford, representing himself, filed a motion to correct a clerical error in the judgment, arguing that it did not accurately reflect the court's oral pronouncement of sentence because the court did not mention the other counts at the resentencing hearing. He contended that the judgment should be corrected to order that the consecutive sentences for the murder counts run concurrently with the sentences for the other counts. The district court denied Shackelford’s motion, ruling that the written judgment accurately reflected the oral pronouncement of sentence.On appeal, the Supreme Court of the State of Idaho reversed the district court's decision. The Supreme Court held that when there is a difference between the oral pronouncement of sentence and the written judgment, the oral pronouncement controls. The court found that the district court's oral pronouncement at Shackelford’s resentencing was unambiguous as far as the murder counts were concerned, but did not mention the other counts. Therefore, while the murder sentences run consecutively to each other, because the district court did not state that the other counts were to run consecutively to the murder counts, they will run concurrently with the murder counts. The case was remanded to the district court to correct the judgment to conform to the oral pronouncement of sentence. View "State v. Shackelford" on Justia Law

The case involves Jameel Fakhri Al Muthafar, who was convicted for aggravated assault and attempted strangulation. Al Muthafar argued that the district court erred by denying his motion to dismiss the information after the magistrate allowed hearsay statements at the preliminary hearing over his objection. The statements were made by a nurse during a dual medical and forensic examination. Al Muthafar contended that without these inadmissible statements, there was insufficient probable cause to bind the case over to the district court. He also argued that the district court abused its discretion in sentencing him to a unified sentence of fifteen years, with five years fixed.The district court denied Al Muthafar's motion to dismiss the commitment and information, arguing that the statements fell under the Rule 803(4) hearsay exception because the State failed to establish that the victim's statements were made for the purpose of medical treatment. The case proceeded to a jury trial where both the nurse and the victim testified. At the conclusion of the trial, the jury found Al Muthafar guilty of both aggravated assault and attempted strangulation. The district court subsequently sentenced Al Muthafar to fifteen years with the first five years fixed.The Supreme Court of the State of Idaho affirmed the district court's decision. The court held that while the magistrate court erred in admitting the nurse's testimony at the preliminary hearing, Al Muthafar's judgment of conviction should nevertheless be affirmed because he received a fair trial. The court also held that the district court did not abuse its discretion by imposing a unified term of fifteen years with five years fixed. View "State v. Al Muthafar" on Justia Law

In June 2016, Peter Franklin Goullette was driving with his child in the backseat when he struck and killed Kathy Stelzer and severely injured Zualita Updike, who were walking on the road. Goullette admitted to officers that he was attempting to buckle his son back in when he struck the victims. He was charged with vehicular manslaughter and reckless driving. Goullette entered a guilty plea while maintaining his innocence, known as an Alford plea. He later appealed his conviction, arguing that the district court abused its discretion when it accepted his guilty plea because it failed to inquire into the factual basis of his guilty plea.The case was first heard in the District Court of the First Judicial District of the State of Idaho, Bonner County, where Goullette was convicted. He then appealed to the Idaho Court of Appeals, which affirmed his conviction. Goullette subsequently filed a petition for review with the Supreme Court of the State of Idaho.The Supreme Court of the State of Idaho affirmed Goullette's conviction. The court held that the district court did not err in accepting Goullette’s Alford plea because the record as a whole demonstrated that Goullette entered a knowing, voluntary, and intelligent plea. The court also held that the district court did not err by failing to revisit the validity of Goullette’s plea at sentencing because the district court was not presented with evidence raising an obvious doubt as to Goullette’s guilt. View "State v. Goullette" on Justia Law

The defendant, Britian Lee Barr, was charged with eleven counts of sexual exploitation of a child for possessing child pornography. Barr had previously been convicted of felony possession of sexually exploitative material in 2011. On the second day of trial, Barr pleaded guilty to five counts of sexual exploitation of a child for possessing child pornography and admitted to being a repeat offender. In exchange for his guilty pleas, the other counts were dismissed. Barr was sentenced to five, fifteen-year fixed sentences to run consecutively, resulting in an aggregate seventy-five-year fixed sentence. The consecutive nature of the sentences was mandated by Idaho Code section 19-2520G(3).Barr appealed the sentence, arguing that the district court abused its discretion by failing to perceive that it had discretion to designate indeterminate portions for the mandatory fifteen-year sentences and that it had discretion to order the sentences be served concurrently. The Supreme Court of the State of Idaho affirmed the decision of the district court because Barr had not preserved his arguments for appeal. Barr returned to the district court and filed a Rule 35(a) motion to correct an illegal sentence. Barr argued that the consecutive sentence requirement in Idaho Code section 19-2520G(3) is unconstitutional because it violates the doctrine of separation of powers by usurping the judiciary’s inherent power to determine whether a sentence runs consecutively or concurrently. The district court denied the motion, concluding that the legislature is empowered to designate mandatory consecutive sentences under the plain language of Article V, section 13 of the Idaho Constitution. Barr timely appealed.The Supreme Court of the State of Idaho held that determining whether a sentence is to be served consecutively or concurrently is not a power reserved exclusively to the judiciary. As a result, section 19-2520G(3) does not violate the separation of powers provision of the Idaho Constitution. The court affirmed the district court's decision denying Barr's Rule 35(a) motion. View "State v. Barr" on Justia Law

In July 2018, Heather Lee Hawking rented a room at a Super 8 hotel in Boise, Idaho, where she housed approximately fifty cats. Over five days, the cats caused extensive damage to the room. Hawking was subsequently charged with and convicted of misdemeanor malicious injury to property. After the incident, the hotel was sold to a new owner. Following Hawking's conviction, the magistrate court conducted an evidentiary hearing to determine restitution owed to the victim. Hawking appealed the Order for Restitution and Judgment.The magistrate court awarded the new owner of the Super 8 hotel $3,708.40 in restitution, reasoning that the new owner took the property in a damaged condition due to the real estate contract and "stepped into the shoes of the previous owners" through that contract. Hawking appealed this decision to the district court, which affirmed the magistrate court's order. Hawking then appealed to the Idaho Court of Appeals, which also affirmed the district court's decision. Hawking subsequently petitioned the Supreme Court of the State of Idaho for review.The Supreme Court of the State of Idaho reversed the district court's order affirming the magistrate court's restitution award. The court found that the State failed to establish that Super 8 was an entity or an assumed business name of a person or entity, and that Super 8 suffered economic loss or injury as a result of Hawking's criminal conduct. The court concluded that the State's failure to establish these elements was fatal to its restitution claim. The court remanded the case to the district court with instructions to vacate the Order for Restitution and Judgment and remand the matter to the magistrate court for further proceedings consistent with this opinion. View "State v. Hawking" on Justia Law

The case revolves around Jeffrey Marsalis's appeal for post-conviction relief based on claims of ineffective assistance of counsel. Marsalis was convicted of rape in 2009, a decision upheld by the Idaho Court of Appeals. He then filed a petition for post-conviction relief, alleging that his trial counsel was ineffective for failing to advise him of his 120-day speedy trial right under the Interstate Agreement on Detainers and for not hiring an expert witness to support his "blackout defense." The district court denied Marsalis's petition for post-conviction relief.The case was previously reviewed by the District Court of the Fifth Judicial District of the State of Idaho, Blaine County. The district court summarily dismissed Marsalis's petition after concluding that there was not a genuine issue of material fact regarding any of Marsalis's claims. Marsalis appealed the dismissal, and the Supreme Court of the State of Idaho affirmed in part and reversed in part. The Supreme Court concluded that the district court erred in summarily dismissing the claims that trial counsel was ineffective for failing to present an expert witness to discuss the scientific basis behind Marsalis's blackout defense, and for failing to inform Marsalis of his speedy trial rights under the Interstate Agreement on Detainers.In the Supreme Court of the State of Idaho, the court affirmed the district court's judgment. The court found that Marsalis failed to establish prejudice on his ineffective assistance of counsel claim concerning the Interstate Agreement on Detainers' 120-day speedy trial timeframe. The court also found that Marsalis failed to establish prejudice on his ineffective assistance of counsel claim concerning his trial counsel's failure to retain an expert witness. The court concluded that Marsalis failed to demonstrate a reasonable probability that the charges against him would have been dismissed with prejudice had trial counsel asserted his speedy trial rights at the December 1 hearing. The court also concluded that Marsalis failed to demonstrate a reasonable probability that, if an expert had provided some additional explanation concerning the scientific bases for blackouts, the jury would have found him not guilty. Therefore, the court affirmed the district court's dismissal of Marsalis's petition for post-conviction relief. View "Marsalis v. State" on Justia Law

The case revolves around Cyrus Wolf Buehler, who was convicted for aggravated driving under the influence (DUI) after a collision with a motorized bicycle, resulting in severe injuries to the cyclist, Raymond Hanson. Buehler was found to have a blood alcohol concentration (BAC) of .181 and .179 at the time of the incident. He sought to introduce evidence suggesting that Hanson's conduct was a superseding, intervening cause of the collision, arguing that Hanson was speeding, under the influence, and his bicycle lacked a headlight. Buehler also challenged the admissibility of his BAC results, as the officer who administered the test had an expired certification.The District Court of the Sixth Judicial District of the State of Idaho denied Buehler's motions, ruling that the evidence he sought to introduce was irrelevant to the determination of whether his act of driving under the influence had some causal connection to Hanson’s injuries. The court also held that the officer’s lapsed certification did not require exclusion of Buehler's BAC results, as the State could establish the foundation for the admission of the evidence through expert testimony. Buehler's conviction was affirmed.On appeal, the Supreme Court of the State of Idaho upheld the lower court's decision. The Supreme Court held that Hanson's conduct was not relevant to the determination of whether Buehler's act of driving while under the influence had some causal connection to Hanson’s injuries. The court also affirmed the lower court's decision to admit Buehler's BAC results, ruling that the officer's lapsed certification did not affect the validity of the BAC results. The court concluded that the district court did not err in its rulings, and Buehler's judgment of conviction was affirmed. View "State v. Buehler" on Justia Law

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