Justia Idaho Supreme Court Opinion Summaries

Paul Stonecypher was stopped by law enforcement for vehicle equipment violations while driving through Idaho on a trip from California to Montana. Stonecypher contended his seizure was unlawfully prolonged to allow for a sniff of the vehicle by a drug-detection dog. After review of the trial court record, the Idaho Supreme Court disagreed, finding the extension of the stop was justified by reasonable suspicion of illegal drug activity. View "Idaho v. Stonecypher" on Justia Law

In September 2018, Customs and Border Protection (“CBP”) officers arrested Darren Temple in California as he crossed the border from Mexico into the United States. Temple had been in Mexico for legitimate business purposes, but CBP officers received a positive alert for his name from the National Crime Information Center indicating that Temple was wanted in Idaho on an outstanding warrant for lewd and lascivious conduct with a minor. Prior to his arrest, Temple had filed for a divorce from Jennifer Temple in March 2018. Then, in May 2018, Jennifer’s daughter, J.P., filed a report with the Canyon County Sheriff’s Office alleging that Temple, her then stepfather, had sexually abused her. Though J.P. did not report the sexual abuse to law enforcement for some time, she testified that she had told her best friend, her boyfriend, and her mother, Jennifer, immediately following the last incident of sexual abuse in late November 2014. After encouragement from her therapist, J.P. eventually reported the incident to law enforcement in May 2018. Two days after his CBP arrest, Idaho charged Temple with one count of lewd conduct with a minor under sixteen. Under the case caption and case number of his criminal case, Temple served Jennifer’s divorce attorney with a subpoena duces tecum seeking “any and all documents related to the billing and payment records related to the representation of Jennifer Temple, to include, but not limited to the number of hours worked and the number of hours charged.” Jennifer’s attorney moved to quash the subpoena , arguing the requested records contained attorney-client privileged information and attorney work product. Temple did not respond to the motion to quash his subpoena. The district court granted the motion to quash, concluding the information sought was irrelevant and, alternatively, covered by the attorney-client privilege. Temple appealed the subpoena issue to the Idaho Supreme Court. Finding no reversible error in the decision to quash, the Supreme Court affirmed. View "Idaho v. Temple" on Justia Law

The State challenged a district court’s order denying a motion to exclude expert testimony that defendant-respondent Ruben Diaz lacked the mens rea to commit aggravated battery because he suffered from a mental illness or defect that caused him to believe the victim was not a person but instead an alien being from another planet. The State charged Diaz with aggravated battery, use of a deadly weapon in the commission of a crime, and resisting and obstructing a police officer after he stabbed a man in a random attack. The State filed a motion in limine to exclude Diaz’s expert testimony, arguing Idaho Code section 18-207 barred expert testimony on evidence of a mental condition. The district court denied: (1) the motion in limine; (2) the State’s subsequent motion to reconsider; and (3) the State’s motion for a permissive appeal. The State then timely filed a motion for permissive appeal to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Diaz" on Justia Law

Talon Ross appealed a district court’s order revoking his probation and imposing his previously suspended sentence for a robbery he pleaded guilty to in 2011. In 2019, Ross was charged with violating the terms of his probation by allegedly committing petit theft and injury to a child. At an evidentiary hearing on the probation violation allegations, the district court found that, despite Ross introducing a judgment of acquittal for the petit theft charge, the State had proved by a preponderance of the evidence that Ross had committed petit theft. Additionally, the district court found by a preponderance of evidence that Ross had committed injury to a child. The Idaho Court of Appeals affirmed the district court’s order revoking Ross’s probation and imposing his sentence. While the Idaho Supreme Court determined the district court did not err in concluding Ross committed the crime of petit theft by a preponderance of the evidence, district court erred in concluding Ross committed injury to a child by a preponderance of the evidence. Judgment was reversed and the matter remanded for a new probation violation hearing. View "Idaho v. Ross" on Justia Law

Aaron Tower appealed a district court’s order denying his motion to suppress evidence obtained following a warrantless arrest. In 2018, Tower’s mother, Michelle, contacted the Boise Police Department (BPD) and spoke to Officer Hilton to report that her son, Tower, had threatened to “blow his head off in [her] house.” The State also alleged that Tower posted on social media that he was driving from Nevada to Idaho with a plan to shoot Michelle and his stepfather. Michelle was out of town at the time. Tower’s grandmother, Sandra, was at home, however, because she was watching the house while Michelle was away. Michelle told Officer Hilton she was concerned for Sandra’s safety and said she did not want Tower on her property. Tower was charged with possession of a controlled substance and with resisting or obstructing an officer. Tower moved to suppress on the grounds the evidence was fruit of an unlawful seizure not based on probable cause. At the hearing on Tower’s motion, Dustin and Michelle both testified. Dustin testified to telling Tower he was under arrest for trespassing, and subsequently placing him under arrest for resisting and obstructing after Tower resisted Dustin’s efforts to handcuff him. Tower argued he was unlawfully arrested for trespassing without probable cause or a warrant, thus, the evidence obtained during a subsequent search should have been suppressed. The Idaho Court of Appeals affirmed his conviction. Tower then petitioned the Idaho Supreme Court for review. The Supreme Court affirmed the district court's decision denying Tower's motion to suppress because Tower did not properly preserve his argument on appeal. View "Idaho v. Tower" on Justia Law

The Idaho Industrial Commission appealed the dismissal of motion to renew a restitution order in a criminal case. The Owyhee County Prosecuting Attorney obtained an order of restitution against Malinda Poe in 2005, which required Poe to pay $2,346 to the Industrial Commission’s Crime Victims Compensation Program. In 2010, the Industrial Commission sought an order renewing the order of restitution, which was granted by the magistrate court. Five years later, the Industrial Commission sought another order renewing the order of restitution, which was also granted at that time by the magistrate court. In 2020, the Industrial Commission sought a third order renewing the order of restitution. This time, however, the magistrate court denied the request, finding that the Industrial Commission lacked standing to seek a renewal of the restitution order. The Industrial Commission appealed to the district court, which, sitting in its intermediate appellate capacity, also concluded the Commission lacked standing, and further concluded that the order of restitution was not subject to renewal pursuant to Idaho Code section 10-1110. The Industrial Commission appealed to the Idaho Supreme Court. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Idaho v. Poe" on Justia Law

Alejandra Ochoa was convicted by jury of misdemeanor vehicular manslaughter. She appealed her conviction to the district court, which vacated the judgment of conviction and remanded the case for a new trial. The district court held that the magistrate court erred in excluding certain toxicological evidence, refusing to grant defendant’s request to continue the trial, and allowing the State’s pathologist to testify. The State appealed the district court’s decision. The Idaho Supreme Court determined the district court erred in reversing the magistrate court’s decision to not admit the results of the toxicology report, and erred in reversing the magistrate court's denial of the motion for a continuance. Further, the Court found the district court erred in reversing the magistrate court’s decision to allow the forensic pathologist to testify concerning the cause of death. The case was remanded to the district court with instructions to reinstate Ochoa's judgment of conviction. View "Idaho v. Ochoa" on Justia Law

Michael McDermott appealed his conviction for second-degree murder. McDermott arrived at his ex-girlfriend’s home late at night in the hopes of obtaining methamphetamine. After finding another man, Robert Waholi, inside the ex-girlfriend’s recreational vehicle (“RV”), McDermott slammed his ex-girlfriend’s head twice in her front door, causing her to fall. McDermott exited the RV and then, a few moments later, Waholi came out carrying a large double-edged axe. McDermott shot Waholi through the heart, killing him. McDermott eventually confessed to the police that he had killed Waholi; however, he claimed he was acting in self-defense. The Idaho Supreme Court determined the district court erroneously instructed the jury on the concept of malice, rendering McDermott's trial unfair. The conviction was vacated, and the case remanded for a new trial. View "Idaho v. McDermott" on Justia Law

Tyler Clapp appealed his conviction for driving under the influence. After stopping Clapp for “spinning cookies” in a parking lot, police became suspicious that Clapp was intoxicated. Clapp refused to submit to any field sobriety tests. Police then obtained a warrant for a blood draw, which showed that Clapp’s blood alcohol content (“BAC”) was 0.152 several hours after initially detaining him. At trial, the State sought to introduce the results of the blood draw. Over Clapp’s objection, the district court allowed the nurse who conducted the blood draw to testify telephonically to his qualifications in order to lay sufficient foundation to admit the results of the blood draw. The results of the blood draw were ultimately admitted, and the jury convicted Clapp of driving under the influence. Clapp appealed. The Idaho Supreme Court found the telephonic testimony violated Clapp’s right to confrontation, "'the face-to-face confrontation requirement is not absolute does not, of course, mean that it may be easily dispensed with. ... [A] defendant’s right to confront accusatory witnesses may be satisfied absent a physical, face-to-face confrontation at trial only where denial of such confrontation is necessary to further an important public policy and only where the reliability of the testimony is otherwise assured.' Both requirements must be met." Further, the Supreme Court determined the State failed to meet its burden establishing harmless error. The conviction was vacated and the matter remanded for further proceedings. View "Idaho v. Clapp" on Justia Law

This appeal consisted of two consolidated cases concerning drug-related charges. Casey Casper appealed his sentence, arguing it was excessive in light of mitigating factors he claimed the district court failed to properly consider. Casper also challenged certain restitution costs awarded to the State, claiming that they were unlawful under a plain interpretation of Idaho Code section 37- 2732(k). After review, the Idaho Supreme Court determined the district court did not abuse its discretion by imposing a ten-year sentence with three years fixed. The Supreme Court affirmed Casper's conviction and the resulting sentence and order of restitution. View "Idaho v. Casper" on Justia Law