Justia Idaho Supreme Court Opinion Summaries

Daniel Ehrlick appealed his conviction for the first-degree murder of a child and the failure to report the death to law enforcement. In the summer of 2009, the Ada County Sheriff's dispatch received an emergency call from Ehrlick reporting that R.M., the eight-year-old son of his live-in girlfriend, Melissa Jenkins, was missing. Ehrlick told dispatchers that R.M. was last seen at 7:00 p.m. on July 24, he had been searching for R.M. for several hours, and everyone was telling him that R.M. was at a birthday party. In the ensuing days, an extensive search was launched to find R.M. The searchers included members of several law enforcement agencies and dozens of citizen volunteers. R.M.'s body was found on August 3, 2009, floating face down in a canal. A large rock was stuffed into a closed cargo pocket of his pants. No evidence was offered as to how, or precisely when, R.M.'s body was placed in the canal. R.M.'s corpse exhibited extensive injuries, including multiple compression injuries to the abdomen and a blow to the head. Both the compression injuries and the head injury were potentially fatal wounds on their own, but would not have resulted in instantaneous death. The State's forensic pathologist testified that R.M.'s death was caused by blunt force trauma to the head and torso due to an assault. Investigators began to suspect Ehrlick and Jenkins were involved in R.M.'s disappearance. Investigators searched the couple's apartment and found a piece of paper taped to a wall which concealed a hole in the drywall. Investigators eventually had the section of drywall scanned in order to create a three dimensional plastic model that was introduced at trial. Investigators suspected that the hole was created when Ehrlick slammed R.M.'s head into the wall. A grand jury returned an indictment charging Ehrlick with first-degree murder and failure to report a death to law enforcement. After trial, a jury unanimously found Ehrlick guilty of both charges. The district court sentenced Ehrlick to two fixed consecutive life sentences. On appeal, Ehrlick argued that the trial court committed multiple errors in the admission of evidence and that the prosecution violated his Fourteenth Amendment right to a fair trial by committing multiple acts of prosecutorial misconduct. Finding no error, the Supreme Court affirmed. View "Idaho v. Ehrlick" on Justia Law

John Doe and his wife had two children born during their marriage. They later divorced, and the children’s mother died from strangulation in 2011. Doe was arrested and charged with murder in connection with her death. He had been held in custody since his arrest. A jury found John Doe guilty of murder in the first degree, for which he was sentenced to life in prison without eligibility for parole during the first twenty-five years. He appealed his conviction. The children’s maternal grandparents were appointed their temporary guardians, and filed this action to terminate John Doe’s parental rights. While Doe was still appealing his sentence for murder, the guardians filed an amended petition adding a claim to adopt the children. The magistrate court tried the claim to terminate John Doe’s parental rights. The court issued its findings of fact, conclusions of law, and order finding that termination of John Doe’s parental rights was in the best interests of the children and that three statutory conditions existed justifying the termination. Doe then timely appealed. In 2015, the Supreme Court entered a decision vacating the jury verdict finding John Doe guilty of murder and his judgment of conviction because the district judge wrongly excluded evidence that the jury could have found corroborated his testimony that he did not kill the children’s mother. Because the judgment was based solely upon the jury verdict finding John Doe guilty of murdering the children’s mother and his judgment of conviction, both of which were vacated on his appeal in the criminal case, the Supreme Court vacated the judgment terminating his parental rights and remanded this case for further proceedings. View "Dept. of Health & Welfare v. John Doe (2014-26)" on Justia Law

The appeal in this case arose after a jury found Desiree Eliasen guilty of misdemeanor stalking. Following the jury’s verdict, Eliasen moved the magistrate court for a judgment of acquittal, which the magistrate court denied. Eliasen subsequently appealed to district court, arguing the State failed to prove she engaged in "repeated acts" constituting a "course of conduct" under the statute. The district court upheld the jury’s verdict and Eliasen appealed. The Idaho Court of Appeals affirmed, and Eliasen then petitioned the Supreme Court for review. On review, Eliasen argued that there was insufficient evidence to show that she was guilty of misdemeanor stalking because she did not engage in separate instances of stalking. Instead, Eliasen claimed her conduct was one continuous act and therefore insufficient to satisfy the "course of conduct" element under the misdemeanor stalking statute. Finding no reversible error, the Supreme Court affirmed the district court’s decision upholding the jury’s verdict. View "Idaho v. Eliasen" on Justia Law

Defendant-appellant Kenny Struhs pled guilty to vehicular manslaughter, was sentenced to a unified term of fifteen years in prison with ten years fixed, and was ordered to pay restitution to the victim's widow, including an amount compensating her for health insurance premiums she paid for coverage between the time of the accident and the time of Struhs' sentencing. On appeal, Struhs challenged the sentence as excessively harsh and the award of restitution for insurance premiums as unauthorized under Idaho Code section 19-5304. Finding no cause to disturb the trial court's judgment, the Supreme Court affirmed. View "Idaho v. Struhs" on Justia Law

Defendant-appellant Katherine Stanfield was convicted by jury for first degree murder of two year-old W.F. by aggravated battery of a child under twelve years. Defendant raised two issues on appeal: (1) the district court erred in admitting certain expert testimony, claiming that the testimony's admission violated her Sixth Amendment right to confrontation and that the evidence was inadmissible hearsay; and (2) the district court deprived her of her Fourteenth Amendment right to due process and right to a jury trial by failing to properly instruct the jury. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Stanfield" on Justia Law

The Idaho Supreme Court granted a petition for review of a Court of Appeals decision in this case. Irwin Adams appealed a district court’s decision summarily dismissing his post-conviction relief petition, which the Idaho Court of Appeals affirmed. Adams argued on appeal that the district court erroneously: (1) weighed the State’s accident reconstruction expert’s trial testimony against Adams’s accident reconstruction expert’s affidavits; (2) reached its own conclusions as to purported flaws in Adams’s accident reconstruction expert’s conclusions; and (3) wrongfully determined that even if Adams’s accident reconstruction expert’s testimony would have been presented at trial, it would not have changed the outcome of the case. Adams also argued that the district court erred when it dismissed the claim that trial counsel was ineffective for failing to investigate and present evidence that Adams’s vehicle was incapable of going the speeds the State alleged during trial. Finding no reversible error, the Supreme Court affirmed the district court’s decision. View "Adams v. Idaho" on Justia Law

A jury found Azad Haji Abdullah guilty of first-degree murder, first-degree arson, three counts of attempted first-degree murder, and felony injury to a child. The case proceeded to sentencing and the jury found two aggravating circumstances. The jury also found that all the mitigating circumstances when weighed against each aggravating circumstance individually were not sufficiently compelling to make the death penalty unjust. The district court subsequently entered judgments of conviction and sentenced Abdullah to death for first-degree murder and to a total of eighty years imprisonment for the remaining five convictions. Abdullah sought post-conviction relief. After an evidentiary hearing, the district court dismissed Abdullah’s petition for post-conviction relief in its entirety. Abdullah appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed the convictions, the sentences, and the order denying post-conviction relief. View "Georgia v. Abdullah" on Justia Law

In 2011, Corey Thiel was charged with felony domestic battery. Pursuant to a plea agreement, Thiel pled guilty to an amended charge of misdemeanor domestic battery and was placed on supervised probation. Approximately one week after entry of this guilty plea, Thiel was charged with a misdemeanor violation of a no-contact order for an incident that occurred while the battery charge was pending. Thiel pled guilty to violating the no-contact order, and the magistrate court imposed suspended jail time and two years of unsupervised probation, while crediting time served. Under the terms of his probation, Thiel was required to comply with the terms of supervised probation established in the underlying battery case. Less than two months thereafter, on May 2, 2012, the State moved for the court to issue a bench warrant for Thiel’s arrest based on probation violations. At a hearing on the State’s motion, Thiel admitted the violations. The court reinstated Thiel on probation. Approximately four months thereafter, the State moved for a second set of probation violations, alleging that Thiel failed to maintain contact with his assigned probation officer and also failed to provide documentation that he had completed the required domestic violence treatment. At a hearing on the State’s motion, Thiel admitted the violations. The court revoked Thiel’s probation and imposed his original sentence of 356 days, with a credit of 67 days. Fifty-five days before his sentence was to end, the Ada County Sheriff’s Office submitted a letter to the magistrate court recommending that Thiel be granted early release. The magistrate court denied the Sheriff’s request. The issue this case presented for the Supreme Court's review was one of statutory interpretation: Idaho Code section 20-621 authorizes commutation of county jail sentences for good behavior, making county inmates with good records while incarcerated eligible for five (5) days off for each and every month of their sentence. A prisoner’s eligibility, however, was conditioned upon receiving a recommendation from the supervising county sheriff. The primary issue presented here was whether the statute vested the magistrate court with the discretion to reject a recommendation from a sheriff. The Supreme Court affirmed the district court's conclusion that the statute vested no discretion with the magistrate judge. View "Idaho v. Thiel" on Justia Law

William Wolfe appealed the Idaho County district court’s decisions denying: (1) his motion for a hearing on his motion for reconsideration of his I.C.R. 35 motion to correct an illegal sentence; and (2) his successive Rule 35 motion to correct an illegal sentence. Specifically, Wolfe argued the district court denied his motions based on two erroneous conclusions: that the subject matter jurisdiction issue had been previously adjudicated and that Wolfe could not file a successive Rule 35 motion. Wolfe argued that if the district court had properly considered the merits of his motions, the district court would have found it lacked subject matter jurisdiction over Wolfe’s original criminal proceedings. Accordingly, Wolfe petitioned the Supreme Court to vacate his judgment of conviction and sentence, or alternatively, to remand the case for an evidentiary hearing. After careful consideration of the district court record, the Supreme Court found no reversible errors, and affirmed the district court’s decisions denying Wolfe’s motion for a hearing and his successive Rule 35 motion. View "Idaho v. Wolfe" on Justia Law

The issue this appeal presented for the Supreme Court's review arose from a district court’s denial of Dameniel Owens’s motion for credit for time served. The district court specified that Owens would only receive credit for his prejudgment time served in a county jail on one of his eight counts of issuing a check without funds. Owens argued that Idaho Code section 18-309 plainly and unambiguously required the district court to credit his prejudgment time served to each of his eight counts. Owens further argued that the Supreme Court should have overruled "Idaho v. Hoch," (630 P.2d 143 (1981)), because in that case the Court improperly went beyond the statute’s plain meaning to hold that the legislature intended a defendant could not receive credit for each separate crime. The Supreme Court indeed overruled "Hoch," vacated the district court’s order denying Owens’s motion for credit for time served, and remanded the case for further proceedings. View "Idaho v. Owens" on Justia Law