Justia Idaho Supreme Court Opinion Summaries

Michanglo Smith challenges multiple evidentiary decisions of the district court involving two jury trials. The underlying convictions stem from a violent incident involving Smith and his then girlfriend (“Girlfriend”) on the night of January 27, 2018 and lasted into the morning of January 28, 2018. According to Smith, Girlfriend was attacked by some other person(s) to whom she owed money. In contrast, Girlfriend testified that Smith had attacked, threatened, and attempted to strangle her repeatedly—not some other person(s). In the first trial, after hearing from both Girlfriend and Smith, in addition to multiple witnesses corroborating Girlfriend’s injuries and reported version of events, the jury convicted Smith on all counts except the attempted strangulation charge. The jury was unable to reach a decision on the attempted strangulation charge. The State re-tried Smith on that charge, and after a second trial, a jury found him guilty of attempted strangulation. Smith appealed his convictions and the subsequent restitution order. Finding no reversible error, the Idaho Supreme Court affirmed Smith's convictions. View "Idaho v. Smith" on Justia Law

In August 2020, police interviewed Dr. Daniel Lee Moore (“Moore”) concerning the murder of Dr. Brian Drake (“Drake”), who had been shot in his chiropractic office over five months earlier. Though Moore invoked his right to an attorney at least three times, the interrogation continued. Moore eventually confessed to the crime and was charged with second-degree murder. Following a defense motion, the district court suppressed the confession after finding that Moore’s Miranda rights had been violated. The district court later dismissed the case, concluding that because the State had relied on the tainted confession in the preliminary hearing, there was insufficient evidence to support a showing of probable cause. The State appealed the dismissal, conceding that there was a Miranda violation, but arguing the district court erred in dismissing the case. Although the Miranda violation rendered Moore’s statements inadmissible in the State’s case-in-chief, the State maintains that the statements could still be used to impeach a claim of innocence by Moore if he were to testify at trial. After review, the Idaho Supreme Court affirmed in part and reversed in part. The Court affirmed the ruling that the confession was inadmissible in the State's case-in-chief, but reversed the ruling that the confession would also be admissible for impeachment purposes, should Moore testify at a future preliminary hearing or at trial. The Supreme Court affirmed the district court’s decision granting the motion to dismiss pursuant to Idaho Code section 19-815A. The rulings in this opinion as to the limited admissibility of Moore’s confession would govern any future prosecution of Moore related to the murder of Drake. View "Idaho v. Moore" on Justia Law

After a jury found Jesus Garcia guilty on charges related to a deadly night-club incident, the district court ordered restitution against Garcia in the amount of $162,285.27. In Idaho v. Garcia, 462 P.3d 1125 (2020) (“Garcia I”), the Idaho Supreme Court reversed the district court’s restitution order after determining the district court had not properly considered Garcia’s future ability to repay that amount. On remand, the district court held a second restitution hearing, weighed evidence from before and after remand, and determined Garcia had the foreseeable ability to pay the restitution amount. The district court then reinstated the original order in full. Garcia appealed, arguing the district court’s decision ignored the Supreme Court’s restitution holding in Garcia I, and was not supported by substantial evidence. Finding no reversible error, the Supreme Court affirmed the trial court. View "Idaho v. Garcia" on Justia Law

Gerald Pizzuto, Jr., was convicted of two brutal murders and sentenced to death in 1986. After the Idaho Commission of Pardons and Parole voted 4-3 to recommend that Pizzuto’s death sentence be commuted to life without the possibility of parole, Idaho Governor Brad Little rejected the recommendation, thereby allowing Pizzuto’s death sentence to remain in effect. Pizzuto challenged the Governor’s action by filing an Idaho Criminal Rule 35(a) motion to correct his sentence, and a sixth petition for post-conviction relief. The district court granted both Pizzuto’s motion and petition after finding Idaho Code section 20-1016 was unconstitutional. The State appealed to the Idaho Supreme Court. Finding Idaho Code section 20-1016 was a constitutional expression of the authority granted to the Legislature, the Supreme Court determined the district court erred in granting both Pizzuto’s Rule 35(a) motion and his petition for post-conviction relief. “Both decisions were based on the erroneous grounds that Governor Little lacked authority to reject the Commission’s clemency recommendation because Idaho Code section 20-1016 is unconstitutional. … Because the 1986 amendment to Article IV, section 7, authorizes the legislature to govern the Commission’s commutation powers ‘by statute,’ and Idaho Code section 20-1016 is a proper expression of that authority, we reverse the district court’s orders and remand Pizzuto’s cases for further proceedings.” View "Idaho v. Pizzuto" on Justia Law

Defendant-appellant Ricky Weaver appealed his conviction for solicitation of murder. The State contended Weaver offered to pay a fellow inmate to murder his girlfriend while they were both being held in the Elmore County Detention Center. Weaver was subsequently charged and convicted by a jury. During his trial, Weaver attempted to elicit testimony from another prisoner, Michael Dean, that Wallace had told Dean that he made up the murder-for-hire story against Weaver in an attempt to try to get a “deal” from the prosecutor in his own case. The district court excluded the evidence on the grounds that Dean’s testimony was hearsay and inherently unreliable based on Dean’s own statements. On appeal, Weaver asserts the district court erred by excluding Dean’s testimony because the anticipated testimony: (1) was relevant because it tended to make it more probable that Wallace had not testified truthfully but instead had tried to set Weaver up in order to secure a “deal” from the prosecutor; (2) fit within the “state of mind” exception to the hearsay rule; (3) was proper impeachment of Wallace’s credibility; and (4) had probative value not outweighed by the possibility of unfair prejudice. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Weaver" on Justia Law

Melanie Hall appealed a district court’s modification of a no contact order. In 2015, the State of Idaho charged Hall with felony stalking of her ex-husband, and aggravated assault. Based on the charges, the district court entered a no contact order and set it to expire in 2017. In January 2016, a jury found her guilty of felony stalking, but returned a verdict of not guilty on the aggravated assault count. In March 2016, the district court entered a judgment of conviction, sentencing Hall to a five year unified sentence with the first two fixed. The court also entered an amended no contact order prohibiting Hall from contacting her ex-husband and their two minor children. The new no contact order was sent to expire on March 28, 2021. Hall moved to amend the no contact order twice: once to allow written communication, and another to allow Hall to send Christmas presents to the children. Two days before the order was set to expire, the State moved to extend the order, explaining that Hall’s victims were concerned with the order’s expiration, and that a new charge of violating the no contact order was pending before the district court. An extension was ultimately granted, and Hall appealed, arguing the district court lacked subject matter jurisdiction to modify the order because it had expired by the time the district court entered its order. The Idaho Supreme Court determined the district court had the authority to amend the no contact order because the State’s motion to extend the expiration date was timely filed. Accordingly, the extension was affirmed. View "Idaho v. Hall" on Justia Law

Jesus Blancas was stopped by Idaho State Police Sergeant Chris Elverud. Elverud suspected Blancas of driving under the influence and administered four breath tests, but only one produced a valid result. That test indicated that Blancas’ blood alcohol content (BAC) was nearly three times the legal limit. Elverud then took Blancas to a hospital to collect a blood sample for testing. Blancas refused to consent to the blood draw, and Elverud attempted to reach an on-call magistrate judge to obtain a warrant. After failing to reach the on-call magistrate judge, Elverud instructed hospital staff to draw Blancas’ blood under the exigent circumstances exception to the warrant requirement. The Idaho Supreme Court concluded that warrantless blood draw violated Blancas’ Fourth Amendment rights because the State failed to prove there was insufficient time to obtain a warrant, and therefor, failed to prove exigent circumstances justified the blood draw. View "Idaho v. Blancas" on Justia Law

Brian Hollist challenged a district court’s denial of his motion to suppress evidence. Hollist was arrested in Idaho Falls after an officer approached him while he was sleeping on a canal bank. The officer was responding to check on Hollist's welfare. After advising the officer he did not need medical assistance, Hollist attempted to leave several times; however, each time the officer insisted that Hollist remain. When Hollist declined to identify himself, the officer handcuffed him and ordered him to sit down on the grass. The officer later discovered that Hollist had an outstanding warrant for his arrest. Following his arrest, officers found a glass pipe with white residue and a bag with a small amount of methamphetamine inside. Before trial, Hollist moved to suppress the methamphetamine and pipe, arguing: (1) the officer was not performing a community caretaking function at the time he was detained; (2) the officer did not have reasonable suspicion to detain him; and (3) the eventual discovery of the arrest warrant did not purge the taint of his unlawful seizure. The district court denied Hollist’s motion to suppress. Hollist timely appealed. The Idaho Supreme Court concluded the officer did not have a reasonable suspicion to detain Hollist, and the officer's unlawful seizure of Hollist was not sufficiently attenuated from the discovery of contraband. The district court's denial of Hollist's motion to suppress was reversed and the matter reversed for further proceedings. View "Idaho v. Hollist" on Justia Law

This case involved an investigatory detention of Jeremey Huntley based on a series of tips, corroborated in part, from a known confidential informant that Huntley was trafficking methamphetamine into Idaho. Huntley moved to suppress the methamphetamine evidence found on his person and in his vehicle found during a search after the stop. The district court granted Huntley’s motion after concluding the officers lacked reasonable suspicion for the stop and that it was unlawfully prolonged. The State appealed. The Idaho Supreme Court reversed, finding that the tips and corroboration supplied the officers with reasonable suspicion to stop Huntley, and the stop was not unlawfully extended because the detectives never deviated from the original purpose of the stop. View "Idaho v. Huntley" on Justia Law

The State appealed the district court’s order granting Sunny Riley’s motion to suppress evidence obtained when a drug dog alerted on her vehicle while she was being cited for a traffic offense. Riley’s motion was granted by the district court after it concluded that the police officer’s deviations from the traffic stop measurably and unlawfully extended the duration of Riley’s seizure under the Fourth Amendment. The Idaho Supreme Court reversed, finding that while there were two deviations from the initial course of this traffic stop, the combined deviation was insufficient to change the overall length of the stop beyond the time when the drug dog alerted on the vehicle. When this occurred, it gave rise to a reasonable suspicion of drug activity and allowed officers to continue to investigate. View "Idaho v. Riley" on Justia Law