Justia Idaho Supreme Court Opinion Summaries

Ryan Rawlings went into a Wal-Mart store to steal various items. He selected a large tote, placed it in a shopping cart, filled the tote with small items of merchandise, and covered them with the tote’s lid. He also selected a combination floor lamp and table and placed it in a cart. He then pushed the cart through the self-checkout line without paying for the merchandise, hoping that a cart containing two items that were too large to bag would not attract attention. However, a loss prevention officer had observed Rawlings’s actions. The loss prevention officer called law enforcement. When a sheriff’s deputy arrived, he talked with Rawlings after giving him Miranda rights. The Deputy asked Rawlings whether he had previously committed thefts like this, and Rawlings answered that he had back in Ohio. He stated that he had always been able to take items from Wal-Mart stores in the past without getting caught. Rawlings was charged with petit theft, a misdemeanor, and burglary, a felony. He waived his right to a preliminary hearing on the felony, and he was bound over to answer in the district court. Prior to trial, his counsel moved to dismiss the burglary charge on the grounds that the statute, as applied to Rawlings, violated both the Equal Protection Clause of the Fourteenth Amendment and the Freedom of Speech Clause of the First Amendment. The motion was denied. Prior to trial, the Prosecutor served and filed a notice of the State’s intent to present evidence of Rawlings’s statement regarding his prior thefts, and Rawlings filed and served a motion in limine seeking to exclude that evidence. The evidence was ruled admissible. During a conference in chambers on the morning of the trial, Mr. Logsdon unsuccessfully re-argued the motion in limine. Then the Prosecutor orally moved to dismiss the petit theft charge, and the district court granted the motion. The burglary charge was tried to the jury, which found Rawlings guilty of burglary. He then appealed. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Rawlings" on Justia Law

In January of 2008, a jury convicted Faron Hawkins of two counts of robbery. At trial, Hawkins admitted that he robbed banks but claimed that he did so under duress that stemmed from his previous involvement with various government agencies, including the Central Intelligence Agency (CIA) and Defense Intelligence Agency (DIA). The Court of Appeals determined that the district court erred when it did not “sua sponte order a psychiatric evaluation and conduct a hearing . . . .” The Court of Appeals vacated Hawkins’ judgment of conviction and remanded the case so that Hawkins could undergo a competency evaluation pursuant to Idaho Code sections 18-211 and 18-212. On remand, the district court conducted a competency hearing in late 2010. Two experts had evaluated Hawkins and determined that Hawkins was competent during the entire course of his legal proceedings. In its order of December 6, 2010, the district court found that Hawkins was competent to stand trial in January of 2008. Hawkins appealed to the Supreme Court arguing that the district court’s 2010 retroactive determination that he was competent to stand trial in 2008 violated his due process rights. He also argued that he was not competent to waive his right to counsel and represent himself pro se. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Hawkins" on Justia Law

In 2012, Rayland Brown was charged by indictment with the felony crime of forcible sexual penetration by use of a foreign object. On the second day of Brown’s jury trial, he and the State agreed to a written plea agreement. One of the provisions of the plea agreement was that the charge would be amended to felony domestic battery. On the same date, the State filed an information charging the crime of felony domestic battery, and Brown pled guilty to that charge. The district court sentenced Brown, and in accordance with the plea agreement the court retained jurisdiction for 365 days. A year later, the court entered an order relinquishing jurisdiction, which resulted in Brown being required to serve a prison sentence of at least fifteen years and up to twenty years, with credit for 483 days already served. Brown filed a motion for reconsideration, and the court reduced the mandatory portion of the prison sentence from fifteen years to eleven years. Brown then filed this civil action seeking post-conviction relief on the ground that he received ineffective assistance of counsel in his criminal case. The district court interpreted the alleged ineffective assistance as being that his counsel advised him that he would receive probation after the period of retained jurisdiction and failed to object to the court’s alleged deviation from the plea agreement. The district court dismissed the petition for post-conviction relief because the court in the underlying case did not deviate from the plea agreement and the plea agreement, which Brown signed, notified him that he may not receive probation because it expressly provided that “[a]t the end of the period of retained jurisdiction, the court would be free to exercise or relinquish jurisdiction in its discretion.” Brown then appealed, challenging whether the court in his criminal case had subject-matter jurisdiction. The Supreme Court concluded Brown could not raise that issue for the first time on appeal in this civil action, and affirmed the judgment in this case. View "Brown v. Idaho" on Justia Law

In 1992, Todd Rich was indicted for felony rape, allegedly committed between November 1991 and January 1992; he pled guilty on August 19, 1992; and on October 23, 1992, the district court sentenced him to six years in the custody of the Idaho Board of Correction. The district court retained jurisdiction for 120 days, and ultimately suspended the remainder of Rich’s sentence and placed him on probation. Rich successfully completed his probation on or about March 2, 2004. The following day, Rich filed a motion asking the district court in his criminal case for relief pursuant to Idaho Code section 19-2604(2), which was granted. The district court reduced Rich’s charge to a misdemeanor. The order reducing the charge stated that “the Judgment is hereby deemed a misdemeanor conviction, thereby restoring [Rich] to his civil rights.” At some point, Rich moved to Pennsylvania. He apparently applied for permission to possess a firearm in Pennsylvania. His request was denied by an administrative law judge who ordered: “It appearing that under Idaho law, I.C. 18-310(2), final discharge for a conviction of rape does not restore the right to ship, transport, possess or receive a firearm, the determination of the Pennsylvania State Police that Todd Rich is prohibited under the Uniform Firearms Act, 18 Pa. C.S. 6101 et seq., is upheld.” Rich filed this action seeking a declaratory judgment that he “may lawfully purchase, own, possess or have under his custody or control a firearm under the laws of the State of Idaho.” The State responded by contending that Rich had no standing to seek such relief. The district court dismissed the case on two alternative grounds: (1) Rich did not have standing because no real, substantial, and concrete controversy then existed; and (2) “Idaho Code 18-310(3) provides the mechanism for the restoration of civil rights is through application to the commission of pardons and parole, not through the District Court.” The district court entered a judgment dismissing this action with prejudice. Finding no reversible error, the Idaho Supreme Court affirmed. View "Rich v. Idaho" on Justia Law

Defendant-appellant Jorge Lopez-Orozco was convicted by jury on three counts of first degree murder. The district imposed three concurrent determinate life sentences. Defendant appealed, arguing: (1) the district court erred in finding that his brother was unavailable as a witness at trial and allowing the brother’s preliminary hearing testimony to be read into evidence; and (2) the court erred in allowing the brother’s unsworn written statement to law enforcement to also be read into evidence. Finding neither of these contentions to warrant reversal of defendant’s convictions, the Supreme Court affirmed. View "Idaho v. Lopez-Orozco" on Justia Law

Shortly before midnight on November 14, 2012, Boise Police Officer Ryan Thueson began following Nathan David Neal in a patrol car. Thueson observed Neal drive his pickup onto, but not across, the line at the edge of the roadway (the “fog line”). Thueson continued to follow Neal until, about one mile further west, he saw Neal again drive onto, but not across, the line at the edge of the roadway. According to Officer Thueson’s original report, at the time he observed Neal drive onto the fog line twice. Thueson learned later that there was no fog line and the line actually marked a bicycle lane. Thueson stopped Neal after he turned right. This traffic stop led to Neal’s arrest for driving under the influence of alcohol. He was not ticketed for any traffic violations. Neal moved to suppress, claiming the officer lacked reasonable articulable suspicion of criminal activity to justify a traffic stop. The State argued the officer observed both a misdemeanor (Boise City Code section 10-10-17, which prohibited driving on a bicycle lane) and an infraction (Idaho Code section 49-637, which required drivers to maintain a single lane of travel), and that these observations justified the stop. The State also argued that observing these two instances of driving onto the line on the right, close to midnight, gave the officer reasonable suspicion that the driver was intoxicated, which also justified the stop. After a hearing and reviewing briefs, the magistrate granted Neal’s motion to suppress. The magistrate held there was no traffic violation justifying the stop because Neal did not cross the line and enter another lane. The magistrate also held that driving onto an alleged fog line two times did not create a driving pattern outside the broad range of normal driving behavior, so the officer did not have reasonable suspicion of DUI. Finally, the magistrate found there was no evidence the officer’s observations occurred in Boise, so there was no violation of Boise City Code. The State appealed, and the district court reversed, ultimately concluding that the officer had reasonable suspicion that both “the statute and ordinance were violated by Mr. Neal’s driving upon the fog line and upon the bike lane marker.” Neal appealed, and the Court of Appeals affirmed, ruling that driving on, but not across, an alleged fog line on the roadway violated the state statute requirement that a vehicle remain within its lane. The Supreme Court granted Neal’s petition for review, and held that driving onto but not across the line marking the right edge of the road did not violate Idaho Code section 49-637. Therefore the officer’s stop of Neal was not justified. The Supreme Court reversed the decision of the district court reversing the magistrate’s granting of Neal’s motion to suppress. View "Idaho v. Neal" on Justia Law

This case was the sixth appeal considered by the Idaho Supreme Court following petitioner-appellant Timothy Dunlap’s guilty plea to first-degree murder. The district court summarily dismissed Dunlap’s successive petition for post-conviction relief. Dunlap raised several substantive claims for post-conviction relief. For each claim, he advanced a corresponding claim of ineffective assistance of appellate counsel. After review and finding no reversible error, the Supreme Court affirmed the district court’s summary dismissal of Dunlap’s successive petition for post-conviction relief. View "Dunlap v. Idaho" on Justia Law

The State appealed the magistrate court's dismissal of the State's motion for contempt brought against Luis Juarez for failing to make payments ordered in a juvenile proceeding. In 2002, Juarez admitted to committing an offense that would have been a misdemeanor if he had been an adult. Much time passed and the court entered several orders directing Juarez to pay fees and restitution in varying sums. Eventually, on October 6, 2005, the magistrate court entered its Amended Financial Judgment and Order directing Juarez to pay restitution. Juarez failed to pay, and would fail to appear twice, resulting in bench warrants for his arrest being issued both times. By the second time Juarez came before the magistrate judge, he was over 26-years old, and outside of the juvenile court's jurisdiction. The court reasoned that now that Juarez had been brought in for an adult felony charge, it could no longer hear the contempt proceedings for failing to pay restitution. The district court reasoned that contempt was not available to compel payment of a restitution obligation arising from a proceeding under the JCA because the magistrate court's jurisdiction was conveyed by operation of Idaho Code section 20-505 and withdrawn by operation of Idaho Code section 20-507. The Supreme Court reversed the district court, concluding: (1) the magistrate court had jurisdiction over a charge of misdemeanor contempt under Idaho Code section 18-1801 (and if the offender was under eighteen years of age at the time of the criminal contempt, and the juvenile court exercises its discretion to treat the offense under the JCA, then Idaho Code section 20-507 would operate to terminate the juvenile court's jurisdiction as the proceedings would arise out of the JCA); (2) based on the State's own affidavit, the alleged crime was committed more than four years before these proceedings were commenced; (3) although this action was processed as a criminal case, no complaint was ever filed; (4) despite the lack of a complaint and without a finding of probable cause, the magistrate court issued warrants which resulted in Juarez's arrest; (5) the court's written "Statement of Rights and Explanation of Procedures for Contempt of Court" erroneously advised Juarez that the State bore the burden of proving the contempt "by a preponderance of the evidence;" (6) the court erroneously advised Juarez of the potential penalties upon conviction for misdemeanor contempt (18-1801 did not prescribe the penalty for misdemeanor contempt); (7) the magistrate court did not appear to recognize that Juarez had a right to a jury trial for misdemeanor contempt; and (8) Juarez appeared before the court without counsel, and Juarez discussed his case with the prosecutor without a knowing and voluntary waiver of the right to the assistance of counsel. The Supreme Court reversed the district court's decision affirming the magistrate court's order dismissing the State's motions for contempt. The case was remanded for further proceedings. View "Idaho v. Juarez" on Justia Law

Jesse Riendeau was arrested for driving while under the influence of alcohol by a Coeur d’Alene police officer. The officer transported him to the jail, where the officer asked that Riendeau submit to a breath test for alcohol concentration. He did, and the two tests showed an alcohol concentration in excess of the statutory limit. Riendeau was charged with driving while under the influence of alcohol. Riendeau filed a motion to suppress the results of the breath test on the ground that the breath test constituted a search and that his consent to that search was obtained unconstitutionally by the threat of a civil penalty of $250 and a one-year suspension of his driving privileges and by the false statement that he was required by law to submit to the breath test. On May 6, 2013, he filed a motion in limine seeking to exclude from evidence the result of the breath test because the State Police’s change of the word “must” to “should” in its standard operating procedures resulted in there being no standards to ensure the reliability of the test results. After an evidentiary hearing, briefing, and argument, the magistrate court denied both motions. Riendeau then pled guilty to driving under the influence of alcohol pursuant to a conditional plea agreement which provided that he would enter a conditional plea of guilty, that he could appeal the orders denying his motions, and that if he prevailed on appeal he could withdraw his guilty plea. The court accepted the plea agreement and sentenced Riendeau. He then appealed to the district court, and it affirmed the magistrate court. He then appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Riendeau" on Justia Law

Andrew Garcia admitted to committing an offense that would have been a misdemeanor if he were an adult. He was ordered to pay court costs of $20.00. After Garcia admitted to committing another offense and a probation violation, he was ordered to pay court costs, probation fees, and community service fees. On May 10, 2010, Garcia admitted to committing another offense and was once again ordered to pay court costs and probation supervision fees. After he failed to make those payments, the State filed a motion for contempt. The magistrate court dismissed the motion, concluding that it did not have jurisdiction because Garcia was then over twenty-one and juvenile court jurisdiction was terminated by operation of Idaho Code section 20-507. The State appealed and the district court affirmed the magistrate court’s order. The State appealed the decision of the district court. After review, the Supreme Court concluded the trial court possessed the inherent power to adjudicate Garcia's alleged contempt, and incorrectly dismissed the State's motion for contempt for lack of jurisdiction. The district court was reversed and the case remanded for further proceedings. View "Idaho v. Garcia" on Justia Law