Justia Idaho Supreme Court Opinion Summaries

Robert Kenneth Wilde was charged with two felonies, including trafficking in heroin, and one misdemeanor possession of a controlled substance. One felony charge was dismissed, and Wilde pleaded guilty to trafficking in heroin, with the misdemeanor charge dismissed as part of a plea agreement. The plea agreement included a provision for Wilde to pay drug restitution for investigation costs. Wilde was sentenced to a mandatory minimum of ten years in prison, followed by twenty years indeterminate, and ordered to pay a $15,000 fine and $291 in restitution to the Idaho State Police. The State sought additional restitution for investigative costs, which Wilde contested, citing his lengthy sentence and diminished earning potential.The district court ordered Wilde to pay an additional $2,806.40 in restitution, considering his foreseeable ability to repay. Wilde appealed, and the Court of Appeals held that he waived his right to appeal the restitution order based on his plea agreement. The Court of Appeals also addressed the merits, concluding that Wilde failed to show error in the district court's decision.The Supreme Court of Idaho reviewed the case and disagreed with the Court of Appeals' decision to raise the issue of appellate waiver sua sponte, as the State had not raised it. The Supreme Court found that Wilde's plea agreement did not contain an appellate waiver regarding restitution under Idaho Code section 37-2732(k). On the merits, the Supreme Court held that the district court did not abuse its discretion in awarding additional restitution, as it adequately considered Wilde's foreseeable ability to repay, supported by substantial evidence. The Supreme Court affirmed the district court's restitution order. View "State v. Wilde" on Justia Law

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt in early 2024 due to the inability to establish reliable intravenous access. Following this, Creech filed a petition for post-conviction relief, arguing that any further attempt to execute him would violate his constitutional rights under the Fifth Amendment’s Double Jeopardy Clause and the Eighth Amendment’s prohibition against cruel and unusual punishment.The District Court of the Fourth Judicial District of Idaho dismissed Creech’s petition, construing his Eighth Amendment argument as a challenge to the method of execution, which it determined could not be litigated in a post-conviction action. The court suggested that Creech could pursue his Eighth Amendment challenge through other legal avenues, such as a 42 U.S.C. § 1983 action. The court also addressed the merits, finding that a second execution attempt did not violate the Fifth Amendment as it did not impose more punishment than authorized, nor did it violate the Eighth Amendment as the failed attempt did not involve intentional or malicious infliction of unnecessary pain.The Supreme Court of Idaho affirmed the district court’s dismissal. It held that Creech’s claims were properly raised under Idaho Code section 19-2719 but found no genuine issue of material fact warranting an evidentiary hearing. The court determined that the failed execution did not constitute cruel and unusual punishment under the Eighth Amendment, as the psychological strain and pain experienced were inherent in any execution method. Additionally, the court ruled that a second execution attempt did not violate the Double Jeopardy Clause, as the initial attempt did not complete the punishment authorized by the legislature. Creech’s state constitutional claims were not considered as they were not adequately preserved for appeal. View "Creech v. State" on Justia Law

Adrian Renee Soliz was found unconscious behind the wheel of his vehicle, which was impeding traffic. Concerned, a passerby called 9-1-1, and emergency responders arrived at the scene. They discovered drug paraphernalia on Soliz's lap while providing medical assistance for what was later confirmed to be a drug overdose. Soliz was subsequently charged with possession of a controlled substance, possession of drug paraphernalia, and other related offenses.Soliz filed a motion to dismiss the charges, arguing that under Idaho’s overdose immunity statute (Idaho Code section 37-2739C(2)), he should be immune from prosecution because the evidence was obtained as a result of his medical emergency. The State opposed the motion, contending that the evidence was discovered during a traffic investigation, not solely due to the medical emergency. The district court denied Soliz’s motion, concluding that the evidence was not obtained solely as a result of the medical emergency.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The Court held that the phrase “as a result of” in the overdose immunity statute means that the drug-related medical emergency must be the sole cause of the discovery of evidence. Since the evidence was discovered during both a traffic investigation and a medical emergency response, the statute did not apply. Therefore, Soliz was not entitled to immunity, and the district court’s denial of his motion to dismiss was upheld. View "State v. Soliz" on Justia Law

Jakobe G. Martin was charged with three counts of statutory rape involving a 17-year-old female, K.F., who reported that Martin had raped her on three occasions. Martin allowed K.F., a runaway, to stay at his apartment, where she later accused him of both forced and consensual sexual intercourse. During the investigation, DNA evidence was collected, and K.F. made statements during a forensic interview that conflicted with the DNA results.The District Court of the Fourth Judicial District of Idaho heard the case. The State filed a motion in limine under Idaho Rule of Evidence 412 to exclude evidence of the victim’s sexual history. Martin argued that he should be allowed to use certain evidence for impeachment purposes, specifically to challenge a statement K.F. made during her forensic interview. The district court allowed Martin to inquire about the DNA results but barred the use of the victim’s statements about her sexual history for impeachment, citing Rule 412(b). Martin was convicted of one count of rape and sentenced to a twenty-year term, with seven years fixed and thirteen years indeterminate.The Supreme Court of Idaho reviewed the case. The court held that the evidence Martin sought to introduce was properly excluded under Rule 412(b), which prohibits evidence of an alleged victim’s past sexual behavior unless it falls within specific exceptions. The court also noted that Martin failed to provide the required notice under Rule 412(c). Consequently, the Supreme Court affirmed Martin’s judgment of conviction. View "State v. Martin" on Justia Law

Desiree Elaine Karst was a passenger in a car stopped by police in Kootenai County, Idaho. During the stop, a drug dog alerted to the presence of drugs, and Karst admitted to having drugs in the car. Additional drugs and paraphernalia were found on her at the jail. She was charged with multiple drug offenses and introducing contraband into a correctional facility. Karst moved to suppress the evidence, arguing the stop was impermissibly extended. The district court partially denied her motion, and Karst entered conditional guilty pleas, reserving her right to appeal. She was ordered to pay $569.50 in various court fees.Karst appealed the partial denial of her motion to suppress. The Idaho Supreme Court found the traffic stop was impermissibly extended, reversed the district court’s decision, and remanded the case. Subsequently, the prosecutor dismissed all charges against Karst. Karst then filed a motion to reimburse the fees she had paid, arguing that retaining her funds violated her due process rights. The district court denied her motion, citing a lack of jurisdiction and suggesting she sue each governmental entity that received the fees.The Idaho Supreme Court reviewed the case and held that the district court had both personal and subject matter jurisdiction to consider Karst’s motion for reimbursement. The court found that the State, by initiating the criminal case, had submitted to the district court’s jurisdiction. The court also determined that requiring Karst to file multiple civil suits to recover the fees would impose more than minimal procedures, violating her due process rights. The court reversed the district court’s decision and remanded the case for further proceedings, instructing that Karst should be reimbursed if she proves she paid the fees and her conviction was invalidated. View "State v. Karst" on Justia Law

In 1988, Rodney Araiza was involved in a riot at the Idaho State Penitentiary, during which an inmate named Richard Holmes was murdered. Araiza was charged with first-degree murder and participating in the riot. At trial, the State presented evidence, including testimonies and Araiza’s bloody palm prints, suggesting Araiza's involvement in the murder. Araiza defended himself by claiming he arrived at Holmes' cell after the murder. Despite his defense, Araiza was convicted by a jury on both charges in 1989.After his conviction, Araiza filed a motion for a new trial, presenting new evidence, including a confession from another inmate, Merle LaMere, who claimed responsibility for the murder. However, the district court denied the motion, finding the new evidence unlikely to result in an acquittal. Araiza was sentenced to life imprisonment for murder and 20 years for riot, to be served concurrently. Araiza's subsequent appeals, including a direct appeal, were unsuccessful.In 2019, Araiza filed a petition for post-conviction relief, claiming actual innocence and requesting DNA and fingerprint testing. The district court dismissed the petition, stating that the DNA evidence would not likely prove Araiza's innocence and that his claims were barred by res judicata. Araiza did not receive notice of this dismissal until after the appeal period had expired. He then filed a motion for relief from judgment under Idaho Rules of Civil Procedure 60(b)(1) and 60(b)(6), which led to the district court reentering judgment.Araiza appealed the reentered judgment, but the Idaho Court of Appeals dismissed the appeal as untimely. The Supreme Court of Idaho reviewed the case and concluded that Araiza's appeal was indeed untimely, as his motion for relief from judgment was filed outside the six-month limit for Rule 60(b)(1) motions. Consequently, the Supreme Court dismissed Araiza’s appeal for lack of jurisdiction. View "Araiza v. State" on Justia Law

In 2018, Brian Hollis pleaded guilty to one count of lewd conduct with a minor under sixteen and four counts of sexual exploitation of a child. He also admitted to being a repeat sexual offender, which mandates a fifteen-year minimum term of confinement. The district court imposed an indeterminate life sentence with twenty-five years determinate on the lewd conduct charge and concurrent determinate sentences of fifteen years for each of the sexual exploitation charges. Hollis appealed his conviction and sentence, but the Idaho Court of Appeals affirmed them.Hollis then filed a pro se petition for post-conviction relief, alleging ineffective assistance of trial counsel. The district court appointed the Kootenai County Public Defender to represent him. However, Hollis' conflict counsel filed a motion to withdraw, stating that he was no longer able to "ethically or effectively represent" Hollis due to statements made by the district court judge against conflict counsel in a similar post-conviction case. The district court denied the motion to withdraw and the motion to continue the summary disposition hearing. The district court subsequently granted the State’s motion for summary disposition, holding that Hollis had not supported any of his claims with any admissible evidence.The Supreme Court of the State of Idaho vacated the judgment of the district court, reversed the decisions on the motion to continue and motion to withdraw, vacated the decision granting summary disposition to the State, and remanded for further proceedings. The court held that the district court abused its discretion in denying the motion to withdraw and the motion to continue. The court also ordered the assignment of a new district court judge on remand. View "Hollis v. State" on Justia Law

The case revolves around John Thomas Bujak, who pleaded guilty to grand theft and was placed on probation with the condition of serving thirty days in jail. Bujak scheduled his jail time on weekends to maintain his employment during the week. After serving his first jail stay from Friday morning to Sunday morning, Bujak learned that he would receive credit for two days of jail time. He then moved the district court for credit for time served, arguing that he should receive three days credit because he served time over the course of three calendar days.The district court denied Bujak’s motion, interpreting that the terms of its probation order required Bujak to serve thirty, twenty-four-hour periods in jail. Bujak appealed this decision, arguing that Idaho Code section 18-309 required the district court to award him one day of credit for each partial day of jail time he served.The Supreme Court of the State of Idaho affirmed the district court’s order. The court concluded that neither section 18-309 nor section 19-2603 applies to the calculation of Bujak’s time served. Instead, the court found that Idaho Code section 19-2601(3) controls, which allows a district court to withhold judgment and impose probation terms it deems necessary and appropriate. The court agreed with the district court's interpretation that Bujak was required to serve thirty, twenty-four-hour days in jail as a term of his probation. View "State v. Bujak" on Justia Law

Martin Edmo Ish was convicted of voluntary manslaughter in 2017 and sentenced to 15 years, with 10 years fixed and five years indeterminate. However, his original conviction was later vacated by the Idaho Supreme Court in 2020. After the court's decision became final, Ish's bail was reinstated. Unable to post a bond, he was returned to jail to await his retrial. His second trial was postponed several times due to public safety concerns during the COVID-19 pandemic. Ish repeatedly moved for dismissal of his case citing speedy trial concerns, but his requests were denied. He also moved for a change of venue, which was also denied. His second trial commenced in July 2021, and he was again convicted of voluntary manslaughter. This time, he was sentenced to a fifteen-year unified sentence, with the first 14 years fixed and one year indeterminate, resulting in a fixed sentence four years longer than his original sentence. Ish appealed his conviction and sentence.The Idaho Supreme Court affirmed Ish's judgment of conviction and sentence. The court found that Ish's right to a speedy trial was not violated, as the delays were either neutral or justifiable. The court also found that the district court did not err in denying Ish's motion for a change of venue, as Ish failed to demonstrate that the jury pool was tainted by media coverage. The court further found that Ish did not demonstrate that a juror should have been excused for bias. The court also found that the district court did not err in imposing an unduly harsh sentence, and that the court did not err in denying Ish's Rule 35 motion for leniency following his second sentence. View "State v. Ish" on Justia Law

Benny Dean Campbell was detained by law enforcement while they were investigating a stolen motorcycle. During the detention, a police trooper discovered heroin and methamphetamine in Campbell's backpack. Campbell was charged with two felony counts for drug trafficking and possession of a controlled substance, and two misdemeanor counts for possession of a controlled substance and possession of drug paraphernalia. Campbell filed a motion to suppress the evidence, arguing that by initially placing him in handcuffs, the trooper converted his detention into an unlawful seizure under the Fourth Amendment to the United States Constitution.The district court agreed that Campbell’s detention was a de facto arrest; however, the court also determined that the evidence was admissible under the attenuation doctrine. After the court denied his motion, Campbell entered into a conditional plea agreement that preserved his right to appeal the denied motion. On appeal, he asked the Supreme Court of the State of Idaho to reject the federal attenuation doctrine because Article I, section 17 of the Idaho Constitution affords him greater protections than the federal standard and is incompatible with Idaho’s more expansive exclusionary rule.The Supreme Court of the State of Idaho affirmed the order of the district court. The court agreed with the district court’s conclusion that the State failed to establish that the use of handcuffs on Campbell was a reasonable precaution for the trooper’s safety. However, the court concluded that while the seizure of Campbell was unreasonable, the inevitable discovery exception to the Fourth Amendment makes suppression improper. The court found that even if handcuffs had never been used, the evidence would have been inevitably discovered whether the trooper had followed either parallel path once the trooper walked into the convenience store. Therefore, the court affirmed the district court’s order denying Campbell’s suppression motion on the alternate theory of inevitable discovery. View "State v. Campbell" on Justia Law