Justia Idaho Supreme Court Opinion Summaries

In 2004, Defendant Randy Koivu was charged with possessing methamphetamine. He was found guilty and the district court sentenced him to five years in the custody of the Idaho Board of Correction, with three years fixed and two years indeterminate. The court suspended that sentence and placed Defendant on probation for four years. The terms of probation included that Defendant pay a fine, court costs, public defender reimbursement, and restitution. Defendant later violated the terms of his probation, and the court revoked his probation and committed him to the custody of the Idaho Board of Correction. Defendant was released in 2009. A few months after his release, a deputy court clerk filed an affidavit stating Defendant failed to pay his fines and court costs. The court issued a warrant of attachment to have Defendant seized and brought before the court to show cause why he should not be punished for contempt for failing to pay his fines. No copy of the order was attached to the warrant of attachment, but bail was set and would be released when Defendant posted bail. In 2010, Defendant was pulled over for speeding, and law enforcement arrested him on an outstanding warrant. While searching Defendant at the jail, a baggie of methamphetamine was discovered near his feet. Defendant was ultimately charged again for possession of methamphetamine, and found as a "persistent violator." The prosecuting attorney moved to dismiss the warrant of attachment pursuant to which Defendant had been arrested. The district court dismissed the prosecution's motion for lack of jurisdiction on the 2009 warrant. The lack of jurisdiction was apparently based upon the fact that the district court had not sentenced Defendant to a fine and court costs, but had only ordered him to pay such sums as a condition of probation. Upon the revocation of his probation, Defendant was no longer required to pay them. As a result, the district court issued an order suppressing the methamphetamine. The State then timely appealed. The State asked the Supreme Court to overrule "Idaho v. Guzman," (842 P.2d 660 (1992)) to hold that the good-faith exception to the exclusionary rule applied to violations of Article I Section 17 of the state constitution. Because the State did not show any ground for doing so, the Court declined to overrule that case and affirmed the district court's order suppressing evidence obtained incident to the wrongly issued 2010 warrant. View "Idaho v. Koivu" on Justia Law

Defendant Filip Danney appealed a district court’s denial of his motion to suppress evidence of drugs obtained through the use of a drug dog during a traffic stop. On appeal, Defendant argued that the district court erred in determining that: (1) a proper foundation was laid for the admission of Global Positioning System (GPS) data used in his prosecution; (2) reasonable suspicion existed to justify the warrantless extension of his traffic stop; and (3) the government’s placement of a GPS device constituted an impermissible warrantless search. Because the Supreme Court agreed that the officer had a reasonable articulable suspicion of possible criminal activity justifying the limited detention of Defendant for purposes of a drug dog search, the Court affirmed the district court's decision. View "Idaho v. Danney" on Justia Law

Defendant-Appellant Robert Gurney pled guilty to possession of marijuana with intent to deliver. He then successfully completed drug court. Upon completion, he requested and received a dismissal of the charge. He also requested that the record of his criminal case be sealed, pursuant to I.C.A.R 32(i), on the basis of economic hardship. The district court denied this second request. It subsequently denied Defendant's request to change the caption of this case on appeal to an abbreviated version of his name which would conceal his identity. Defendant appealed both decisions. Upon review, the Supreme Court concluded the district court did not err by denying Defendant's motion to seal his records or amend the caption of his case: "[a]s the district court recognized that the decision was committed to its discretion, recognized and applied the applicable legal standard, and did so through the exercise of reason, [the Court was] unable to conclude that the decision was an abuse of discretion." View "Idaho v. Gurney" on Justia Law

Defendant-Appellant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. Defendant raised several issues on appeal pertaining to the sufficiency of the evidence presented against him at trial, and procedural errors that prejudicially lead to his conviction. Taking each of Defendant's issues raised on appeal, and after a review of the trial record and applicable law, the Supreme Court found that the jury was presented with sufficient evidence from which it could reasonably find that Defendant was guilty of first-degree murder, and that the trial court committed no fundamental errors that adversely impacted Defendant's trial. Accordingly, the Court affirmed Defendant's convictions and sentences. View "Idaho v. Adamcik " on Justia Law

In 2003, Defendant Lonnie Forbes pled guilty to attempted lewd conduct with a minor child under sixteen years of age. The district court withheld judgment three months later and placed Defendant on probation for seven years. As a result of his plea, Defendant was required to register as a sex offender. When Defendant committed the crime, Idaho law permitted him to request to withdraw his guilty plea and have the case dismissed. The district court was given discretion to grant Defendant's request so long as Defendant complied with the terms of his probation. Three years later, the law was amended. Three years after that, Defendant's probation was amended to unsupervised probation, with all other terms of probation still in effect. In 2010 when Defendant met the requirements of his withheld judgment, he moved to set aside his guilty plea and for a restoration of his civil rights. The State opposed Defendant's motion to dismiss, but the district court granted Defendant's request. The State appealed, arguing that the change in the law governing Defendant's sentence and probation barred Defendant's ability to have his case dismissed. Upon review, the Supreme Court held that the district court erred by retroactively applying the amended law to Defendant's case. The district court's decision was vacated and the case remanded for further proceedings. View "Idaho v. Forbes " on Justia Law

Defendant-Appellant Matthew Hanson was convicted of aggravated assault. At the sentencing phase, he exercised his Fifth Amendment privilege against self-incrimination and declined to participate in the preparation of the presentence investigation (PSI) report. Defendant later moved the court to order a presentence psychological evaluation. The district court ruled that unless Defendant agreed to participate in the PSI, his motion would be denied on the ground that a defendant may not selectively invoke his Fifth Amendment privilege with respect to different aspects of a single subject. Defendant again declined to participate, and the court denied his motion. Defendant's attorney subsequently requested a competency evaluation, which was also denied. Defendant was sentenced to five years, with three years fixed. He then moved for reconsideration of his sentence, which motion the district court denied. Defendant appealed the district court's denial of his requests for a psychological evaluation and for a competency evaluation. Upon review, the Supreme Court affirmed the district court's denial of Defendant's request for a competency evaluation. However, the Court reversed the district court's denial of Defendant's request for a psychological evaluation because: (1) the record showed Defendant's mental condition would be a significant factor at sentencing; and (2) it incorrectly held that Defendant could not invoke his Fifth Amendment privilege against self-incrimination with regard to the PSI but waive the privilege in order to obtain a psychological evaluation. Accordingly, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Idaho v. Hanson " on Justia Law

Defendant-Appellant Simona Manzanares appealed the judgment entered after she pled guilty under a conditional plea agreement. She pled guilty to recruiting a criminal gang member in exchange for the dismissal of a charge for providing a firearm to a criminal gang member. On appeal, Defendant argued that the "Recruiting Provision" (I.C. 18-8504(1)(a)) was unconstitutionally overbroad on its face and as applied for encroaching on the First Amendment right to free association; that the "Firearm Provision" (I.C. 18-8505) was unconstitutionally overbroad as applied for punishing her "expressive conduct," and unconstitutionally vague on its face and as applied for failing to adequately define "gang member," as well as being unconstitutional under the Second Amendment of the federal and under Article I, Section 11 of the state constitution. Defendant raised additional constitutional claims, and argued that the evidence presented against her at the preliminary hearing was insufficient to support the charges she faced. Upon careful consideration of Defendant's arguments, the Supreme Court concluded that the "Recruiting" and "Firearm" provisions were not unconstitutionally overbroad nor were they unconstitutional as they applied to Defendant. As such, the Court upheld Defendant's conviction pursuant to her conditional plea agreement. View "Idaho v. Manzanares " on Justia Law

Defendant-Appellant Daniel Johnson petitioned the district court for an exemption from sex offender registration requirements. The district court determined that the 2009 amendments to the Idaho Sexual Offender Registration Notification and Community Right-to-Know Act (SORA) precluded such exemption and therefore denied his petition. On appeal, Defendant argued that the district court’s application of SORA was unconstitutional. Because Defendant filed his petition in his already-dismissed criminal case, the Supreme Court concluded the district court lacked jurisdiction to consider the matter. The Court therefore vacated the district court’s decision. View "Idaho v. Johnson " on Justia Law

Defendant John Joseph Delling appealed his conviction based on his conditional pleas of guilty to two counts of second-degree murder. Defendant was initially charged with two counts of first-degree murder for the deaths of David Boss and Brad Morse. These counts were later amended to second-degree murder. Shortly after being charged, Defendant's counsel motioned for a mental health evaluation to determine whether Defendant was fit to proceed and able to aid in his own defense. Defendant requested that the Supreme Court reconsider and overrule its decision in "State v. Searcy" (798 P.2d 914 (1990)), to find that Idaho's abolition of the insanity defense was unconstitutional. Defendant also asserted that the district court abused its discretion and imposed excessive sentences. Upon careful review of the applicable legal authority and the arguments presented in Defendant's appellate brief, the Supreme Court concluded Defendant had not provided any argument that showed the precedential cases to be wrongly decided, unwise, or unjust. By looking at each argument individually, none of Defendant's constitutional rights were infringed by the abolition of the insanity defense. Furthermore, the Court also found that the sentence imposed by the district court was reasonable and not an abuse of discretion. View "Idaho v. Delling " on Justia Law

Defendant John Schulz appealed his conviction of felony domestic battery and the attempted strangulation of his fifteen-year-old daughter. Both charges required the state to prove that the daughter was Defendant's "household member" as defined by the applicable statute. The district court granted Defendant's motion to dismiss based on the fact that she did not fall within that definition. Because the Supreme Court found that the definition of "household member" plainly limited the application to "intimate partners" and thus, did not extend to a child living with her father, the Court affirmed. View "Idaho v. Schulz " on Justia Law