Justia Idaho Supreme Court Opinion Summaries

On January 22, 2021, officers from the Coeur d’Alene Police Department were patrolling the downtown bar district when they observed James Mark Popp sitting in a parked car and flicking cigarette ash out the window. The officers approached Popp, requested his identification, and subsequently conducted a search after a drug-sniffing dog alerted to the presence of controlled substances. The search revealed cocaine, leading to Popp’s arrest and charges for possession of cocaine, possession of drug paraphernalia, and littering.The District Court of the First Judicial District of Idaho denied Popp’s motion to suppress the evidence obtained during the search, ruling that the officers had reasonable suspicion to detain Popp for littering under local and state laws. Popp entered a conditional guilty plea to the possession charge, preserving his right to appeal the suppression ruling. The Idaho Court of Appeals affirmed the conviction, agreeing that the officers had reasonable suspicion under Idaho Code section 18-7031.The Supreme Court of Idaho reviewed the case and concluded that the officers lacked reasonable suspicion to detain Popp under Idaho Code section 18-7031. The court found that the officers’ observation of Popp flicking cigarette ash in a private parking lot did not constitute reasonable suspicion of littering, as there was no evidence that the property owner prohibited such conduct. Consequently, the court reversed the district court’s order denying the motion to suppress, vacated Popp’s judgment of conviction, and remanded the case for further proceedings. View "State v. Popp" on Justia Law

Amanda Fletcher was arrested after a police officer, Officer Biagi, noticed her vehicle parked outside a convenience store and discovered she had a warrant for her arrest. Upon arresting her, Biagi requested a drug detection dog to sniff the exterior of her vehicle. The dog alerted to the presence of drugs, leading officers to search the vehicle and find methamphetamine and paraphernalia. Fletcher, who was on probation and had waived her Fourth Amendment rights, moved to suppress the evidence, arguing that the Idaho Constitution provides greater protection against dog sniffs and searches than the Fourth Amendment.The District Court of the Fourth Judicial District of Idaho denied Fletcher's motion to suppress, citing her probation agreement, which included a waiver of her rights concerning searches. Fletcher entered a conditional guilty plea, reserving the right to appeal the denial of her motion. She was sentenced to seven years with two years fixed, but her sentence was suspended, and she was placed on probation for seven years. Fletcher then appealed the decision.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's decision. The court held that exterior sniffs of a vehicle by a drug dog are not considered searches under Article 1, Section 17 of the Idaho Constitution. Additionally, the court found that the automobile exception to the warrant requirement does not impose a heightened standard under the Idaho Constitution. The court concluded that the officers had probable cause to search Fletcher's vehicle based on the drug dog's alert, which was sufficient to establish probable cause for a warrantless search. Thus, the district court's order denying Fletcher's motion to suppress was affirmed. View "State v. Fletcher" on Justia Law

Dwayne Edward Best was convicted of possession of a controlled substance with intent to deliver, trafficking a controlled substance, and unlawful possession of a firearm. Best moved to suppress evidence obtained during a warrantless search of his room, arguing it violated his Fourth Amendment rights. The district court denied the motion, and the case proceeded to a jury trial. Before closing arguments, the State moved to preclude Best from discussing the lack of law enforcement body camera footage for a particular interview, which the district court granted. The jury found Best guilty on all charges, and he filed a timely appeal challenging the district court’s denial of his motion to suppress and its decision limiting his closing argument.The Idaho Court of Appeals affirmed the district court’s decision. Best then filed a petition for review, which the Idaho Supreme Court granted. The Supreme Court reviewed whether Best preserved his suppression arguments for appeal and whether the district court erred by limiting his closing argument. The court held that Best failed to preserve his argument regarding the 2018 Terms and Conditions of Probation because he did not raise it before the district court. Additionally, the court found that Best’s alternative argument about the scope of the search was also not preserved for appeal.The Idaho Supreme Court affirmed the district court’s decision denying Best’s motion to suppress, as the search was permitted by the 2018 Terms and Conditions of Probation. The court also held that the district court erred in precluding Best from discussing the lack of body camera footage during his closing argument but concluded that the error was harmless beyond a reasonable doubt. The court found substantial evidence of Best’s guilt beyond a reasonable doubt, excluding the erroneously precluded closing argument. Consequently, the Idaho Supreme Court affirmed Best’s judgment of conviction. View "State v. Best" on Justia Law

In December 2018, Misty Dawn Rose was charged with Delivery of a Controlled Substance and later indicted on additional charges, to which she pleaded guilty. The district court sentenced her to multiple terms, which were to be served consecutively, but retained jurisdiction and sent her on a rider. After successfully completing the rider, Rose was placed on supervised probation. In November 2021, a Probation Violation Report was filed, citing multiple violations, including failure to attend substance abuse treatment and committing a new misdemeanor. The district court issued a bench warrant and, after a hearing, decided to give Rose another chance with a second rider, specifying that she must be admitted to drug court or mental health court to remain on probation.Rose completed the second rider but was not admitted to either treatment court due to eligibility issues. Despite her efforts, she was not accepted into any program. The district court set a probation review hearing, stating that failure to be accepted into a treatment court would be a violation of probation. Rose failed to appear at the review hearing because she was in custody in another county. The district court found her in violation of probation for not being admitted to a treatment court and for failing to appear at the hearing, and subsequently revoked her probation and imposed her sentences.The Idaho Court of Appeals affirmed in part and reversed in part, concluding that Rose's failure to be admitted to a treatment court was not willful but upheld the finding that her failure to appear was willful. The case was remanded for a probation disposition hearing. Rose petitioned for review, which the Idaho Supreme Court granted.The Idaho Supreme Court reversed the district court's order revoking probation, holding that Rose's non-acceptance into a treatment court was not willful and that she was not given proper notice that her failure to appear at the hearing would be a ground for revocation. The judgment imposing her sentence was vacated, and the case was remanded for further proceedings before a different district judge. View "State v. Rose" on Justia Law

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court’s denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith’s motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and subsequent inventory search of his vehicle were reasonable and conducted according to standard police procedures. Smith was convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court’s decision. The court held that the State did not meet its burden to show that the police officer’s decision to impound Smith’s vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. Consequently, the evidence obtained from the search was inadmissible, leading to the vacating of Smith’s conviction. The court emphasized that the impoundment must be reasonable under all circumstances known to the police at the time and must serve a legitimate community caretaking function. View "State v. Smith" on Justia Law

Esequiel Ruiz was charged with grand theft after being seen stealing packages from residences. He pleaded guilty and was sentenced to eight years, with four years determinate, and placed on probation. In September 2021, the State moved to revoke his probation due to violations, including a domestic incident and failure to take mental health medications. Ruiz admitted to the violations, and the district court revoked his probation but retained jurisdiction, placing him in a rider program. In May 2022, the NICI recommended Ruiz for supervised probation, noting his completion of required programming despite some behavior issues. However, the district court relinquished jurisdiction without holding a review hearing or providing an explanation.The Idaho Court of Appeals affirmed the district court's decision. Ruiz then petitioned for rehearing to the Idaho Supreme Court, which was granted. The Idaho Supreme Court reviewed the district court's decision for abuse of discretion, considering whether the court acted within its discretion, followed legal standards, and exercised reason in its decision-making process.The Idaho Supreme Court found that the district court abused its discretion by failing to provide any rationale for relinquishing jurisdiction, making it impossible to review the decision-making process. The court emphasized that while a jurisdictional review hearing is not required, the district court must provide an explanation when there is conflicting evidence in the record. The court vacated the district court's order and remanded the case for the district court to issue appropriate findings consistent with the opinion. View "State v. Ruiz" on Justia Law

Ammon Edward Bundy was convicted of misdemeanor criminal trespass and misdemeanor resisting and obstructing in two separate cases. In the first case, Bundy was observing a committee meeting at the Idaho State Capitol when the meeting was moved due to a disturbance. The Speaker of the House ordered the Lincoln Auditorium to be cleared, but Bundy refused to leave. He was arrested after going limp and requiring troopers to carry him out. In the second case, Bundy returned to the Capitol the day after his arrest, despite receiving a trespass notice prohibiting him from entering the public areas of the Capitol for one year. He was arrested twice on the same day for entering the building and refusing to leave.The district court affirmed Bundy’s convictions in both cases. The court found that Idaho’s criminal trespass statute was not ambiguous and applied to both public and private property. It also determined that the statute was not unconstitutionally vague or overbroad as applied to Bundy’s conduct. The court rejected Bundy’s arguments that the Speaker of the House and the Director of the Department of Administration had unbridled discretion to revoke access to the Capitol. The court also held that Bundy’s arrest was lawful, and his passive resistance did not provide a defense to the charge of resisting and obstructing.The Idaho Supreme Court reviewed the case and affirmed the district court’s decisions. The Court held that the criminal trespass statute provided adequate notice to Bundy that his conduct was prohibited and did not grant unbridled discretion to law enforcement or other state actors. The Court also found that the trespass notice was clear and not unconstitutionally vague or overbroad. Finally, the Court held that Bundy’s arrests were lawful, and his convictions for resisting and obstructing were supported by substantial evidence. View "State v. Bundy" on Justia Law

The case involves Danielle Radue, who appealed her conviction for first-degree murder following the death of her nine-week-old son, D.M. On May 11, 2020, Radue called 911, reporting that D.M. was not breathing. She initially claimed D.M. was in a swing and possibly choking. Later, she admitted to putting D.M. on the ground harder than intended, causing his head to strike the floor. Medical examinations revealed D.M. had a fractured skull and brain bleeding, leading to his death. Radue was indicted for first-degree murder and entered a conditional guilty plea, preserving her right to appeal several pretrial rulings.The District Court of the Fourth Judicial District of Idaho reviewed the case. Radue challenged several pretrial rulings, including the exclusion of expert testimony on her mental state, the admission of prior acts of violence under Rule 404(b), the prohibition of cross-examining the State’s medical expert about a prior case, the denial of funds for an expert on false confessions, the use of the term "victim" at trial, and the limitation on peremptory challenges due to COVID-19.The Idaho Supreme Court reviewed the case. It affirmed the district court’s exclusion of Dr. Cirino’s testimony, agreeing it was an attempt to present an insanity defense, which is not permissible under Idaho law. The court also upheld the admission of prior acts of violence, finding them relevant to the issue of willfulness. The court ruled that the argument regarding cross-examining the State’s medical expert was not preserved for appeal. It found no abuse of discretion in denying funds for an expert on false confessions, as the money judge reasonably concluded there was no coercion. The court also upheld the use of the term "victim," noting it did not inherently imply guilt. Lastly, the court found the challenge to the limitation on peremptory challenges moot following its decision in State v. Harrell, which upheld the reduction due to the pandemic. The Idaho Supreme Court affirmed the district court’s orders and Radue’s conviction. View "State v. Radue" on Justia Law

In April 2021, a confidential informant (CI) working for the Blaine County Sheriff’s Office was introduced to Kelly D. Webb. The CI, at the request of the Sheriff’s Office, attempted to purchase methamphetamine from Webb. Webb sold the CI more than 28 grams of methamphetamine on two occasions, leading to his indictment by a grand jury for two counts of felony trafficking in methamphetamine. Webb pleaded not guilty and filed a motion in limine to present a defense of "charge entrapment," arguing that he was induced by law enforcement to sell a larger quantity of drugs than he intended. The district court denied his motion, and Webb entered a conditional guilty plea, reserving his right to appeal the denial.The District Court of the Fifth Judicial District of Idaho reviewed Webb's motion and held hearings on the matter. The court determined it had the authority to recognize charge entrapment as an extension of the common law defense of entrapment but ultimately declined to do so. The court noted that charge entrapment is a minority position in other jurisdictions and is typically associated with the Federal Sentencing Guidelines, which differ from Idaho’s mandatory minimum sentencing laws. Webb was sentenced to a unified sentence of 7 years, with 3 years fixed, and a $10,000 fine, which are the mandatory minimums for trafficking in methamphetamine.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's decision. The court declined to recognize the defense of charge entrapment, noting that Idaho’s traditional entrapment defense is intended to protect innocent individuals from being induced to commit crimes, which did not apply to Webb’s case. The court also found that the rationale behind charge entrapment in federal cases, which is based on the Federal Sentencing Guidelines, does not apply to Idaho’s mandatory minimum sentencing scheme. Therefore, the court upheld the district court's denial of Webb's motion in limine. View "State v. Webb" on Justia Law

Lea Anne Eaton was arrested and charged with felony burglary under Idaho Code section 18-1401 for using discarded Walmart receipts to return stolen items for a refund. Shortly after her charge, a new statute, Idaho Code section 18-1401A, creating a misdemeanor offense of "commercial burglary," became effective. Eaton filed a motion to reduce her felony charge to the new misdemeanor charge, which the district court denied. Eaton entered a conditional guilty plea, reserving her right to appeal the denied motion, and was sentenced to a unified ten-year sentence with four years fixed. She subsequently filed motions for reconsideration and to correct an illegal sentence, both of which were denied. Eaton appealed these decisions.The Idaho Court of Appeals upheld Eaton's conviction and sentence. Eaton then filed a Petition for Review, which the Idaho Supreme Court granted. The Supreme Court reviewed whether the district court erred in denying Eaton's motion to reduce her charge and her motion to correct an illegal sentence.The Idaho Supreme Court held that the commercial burglary statute, Idaho Code section 18-1401A, was not retroactive and did not apply to Eaton's conduct, which occurred before the statute's enactment. The Court found that the statute created a new offense with distinct elements from the general burglary statute and did not amend the penalties for general burglary. Therefore, Eaton was properly charged and convicted under the general burglary statute, Idaho Code section 18-1401. The Court also held that Eaton's sentence was not illegal, as she was not entitled to the lesser penalty under the commercial burglary statute. Consequently, the Idaho Supreme Court affirmed the district court's judgment and the denial of Eaton's Rule 35(a) motion. View "State v. Eaton" on Justia Law