Justia Idaho Supreme Court Opinion Summaries

The State appealed a district court's judgment granting Defendant Trevor Booth's petition for post conviction relief on the grounds that Defendant received ineffective assistance of counsel. In 2005, Defendant was accused of the shooting death of Leonard Kellum. Defendant was subsequently charged for first-degree murder. The State declined to seek the death penalty in this case. Defendant's attorney prepared a memorandum outlining his understanding of the potential penalties he would face. The attorney discussed the nuances of the statutory aggravating circumstances and the risks associated with taking the case to trial. Defendant then entered into a plea agreement with the State, agreeing to plead guilty first-degree murder. After a failed appeal challenging his sentence, Defendant filed for post-conviction relief. The court concluded that Defendant's attorney erroneously advised Defendant of the consequences of his plea agreement. The Supreme Court found that the district court did not err in concluding that Defendant's attorney was deficient, and that Defendant was prejudiced as a result. The Court affirmed the district court's decision to grant Defendant post-conviction relief. View "Booth v. Idaho" on Justia Law

Defendant Jonathan Ellington appealed his conviction for murder and aggravated battery. He argued on appeal to the Supreme Court that prosecutorial misconduct, evidentiary errors, a biased jury and the "cumulative error doctrine" entitled him to a new trial. The Supreme Court found merit to several of Defendant's claims. The Court found that the district court abused its discretion when it denied Defendant a new trial after evidence came to light that the State's sole rebuttal witness provided false testimony at trial. The Court vacated Defendant's conviction and sentence, and remanded the case for a new trial. View "Idaho v. Ellington" on Justia Law

In 2004, a jury found Petitioner Erick Hall guilty of first-degree murder, kidnapping and rape. Petitioner was sentenced to death. Petitioner appealed his conviction, and was appointed a public defender. In 2005, Petitioner petitioned the district court for post conviction relief. In that proceeding, the district court limited contact between Petitioner's counsel and the jurors that convicted him. Petitioner moved for reconsideration. In 2006, Petitioner moved to depose his trial attorneys and their investigator. The court allowed the deposition of trial counsel, but denied leave to depose the investigator. Petitioner's petition for post conviction relief was ultimately denied. On appeal to the Supreme Court, Petitioner challenged all of the district court's denials pertaining to the interview and deposition of jurors and key witnesses so that he could mount a successful appellate petition for relief. The Supreme Court found that the district court did not abuse its discretion in denying Petitioner's requests. The Court affirmed the district court's decision on all issues. View "Hall v. Idaho" on Justia Law

Petitioner Zack Fields appealed the dismissal of his application for post conviction relief. In 1988, Petitioner was sentenced to death for the stabbing death of Mary Vanderford. Petitioner argued that he was wrongly accused and that DNA test results and affidavits of trial witnesses supported his argument. The district court ordered nineteen latent fingerprints from the murder scene to be run through the national fingerprint database and to have DNA testing of substances found on Petitioner and the victim’s clothing and underneath her fingernails. Testing determined that the fingerprints did not belong to Petitioner, nor did any of the substances contain his DNA. On appeal to the Supreme Court, Petitioner argued that he was entitled to an inference that the victim scratched her attacker because the attacker was close enough to stab her. With no DNA evidence of Petitioner recovered from the murder scene, Petitioner contended the district court erred by not viewing the DNA and fingerprint evidence “in a light most favorable to” Petitioner. The Supreme Court found that there was “nothing but speculation supporting the claim that the scrapings from the victim’s fingernails came from her attacker. We therefore uphold the dismissal of [Petitioner’s] claim . . . because the DNA test results, in light of all admissible evidence, do not demonstrate that [Petitioner] is not the person who committed the murder.” View "Fields v. Idaho" on Justia Law

A State trooper arrested Respondent Jason Miller for DUI. The trooper observed that Respondent’s pupils were dilated and asked that Respondent perform some field sobriety tests, which Respondent ultimately failed. The trooper discovered scissors in Respondent’s pocket that were used for cleaning a marijuana pipe. Respondent admitted to smoking marijuana “every day.” The trooper took respondent to a hospital for a urine test, but at the hospital, Respondent refused to willingly provide a sample. A registered nurse at the hospital then catheterized Respondent at the trooper’s request, and extracted the sample. Respondent later pled guilty to possession of drugs, drug paraphernalia and to DUI. Respondent appealed the trial court’s grant of summary judgment to the State. He argued that his civil rights under 42 U.S.C 1983 and state tort laws were violated when he was “unreasonably” catheterized. The Supreme Court found that because “American search-and-seizure law is undeveloped as to when an officer may administer an involuntary warrantless catheterization on a suspect,” the state trooper was entitled to qualified immunity for both of Respondent’s the federal and state law claims. View "Miller v. Idaho State Patrol" on Justia Law

A grand jury indicted Defendant-Appellant Daniel Lute for "battery with the intent to commit a serious felony," specifically "rape and/or kidnapping." A judgment of conviction was entered, sentencing Defendant to five years in prison to run concurrently with a sentence Defendant was already serving. The judgment did not specify which serious felony Defendant had intended to commit when he committed the battery. Approximately nine years after the expiration of Defendant's sentence, Defendant filed an ICR 35 motion: the Department of Corrections' records incorrectly showed Defendant had committed a sex crime. Defendant wanted to eliminate confusion. The district court granted Defendant's request, and the judgment was amended to reflect the correct sentence. Five months later, Defendant filed a second ICR 35 motion arguing his sentence was invalid under Idaho law, and that the district court lacked subject matter jurisdiction when it entered the judgment, because the grand jury's term had expired at the time he was indicted. The district court denied Defendant's second ICR 35 motion; the appellate court affirmed. The Supreme Court granted Defendant's petition for review, and found that the district court did not have jurisdiction to convict Defendant when the grand jury indicted him. The Court reversed and remanded the case to the lower court to vacate Defendant's conviction. View "Idaho v. Lute" on Justia Law