Justia Idaho Supreme Court Opinion Summaries

Juan Jimenez filed a pro se petition for post-conviction relief and requested that counsel be appointed to represent him under Idaho Code section 19- 4904. In November 2018, Jimenez was charged with felony possession of a controlled and possession of contraband in a correctional facility. Pursuant to a plea agreement, he entered an Alford plea to the controlled substance charge and a judgment of conviction was entered in December 2018. The district court sentenced Jimenez to a three-year unified sentence with the first six months de terminate, to run consecutively to the sentences he was already serving. For his post-conviction relief petition, the district court appointed an attorney to represent Jimenez but limited the scope of his counsel’s representation to a single claim in the petition: his Rule 35 ineffective assistance of counsel claim. Jimenez argued the district court erred by limiting appointed counsel’s representation. To this, the Idaho Supreme Court agreed. Accordingly, the Supreme Court vacated the judgment dismissing Jimenez’s petition, and remanded for further proceedings. View "Jimenez v. Idaho" on Justia Law

The issue presented for the Idaho Supreme Court's review in this case arose from a March 2020 traffic stop where a single officer, without having reasonable suspicion that a crime involving the passenger was afoot, checked the passenger for outstanding warrants. The officer used her patrol vehicle’s computer and received a “hit” for a warrant and arrested the passenger. After the arrest, the officer discovered methamphetamine in the passenger’s purse, the rear of the patrol vehicle where the passenger was seated, and on the passenger’s person. The district court ordered the methamphetamine evidence suppressed after concluding the officer unlawfully extended the traffic stop by checking the passenger for outstanding warrants absent reasonable suspicion or a safety justification particular to that stop. The Supreme Court reversed and remanded the trial court's judgment, finding that the Fourth Amendment permits law enforcement to check passengers for outstanding warrants as a matter of course during traffic stops because of officer safety concerns. View "Idaho v. Wharton" on Justia Law

Cory Campbell appealed his sentence arising from his conviction of two counts of battery with attempt to commit rape. Campbell, who was seventeen at the time, was charged with five felony offenses related to multiple victims: four counts of rape and one count of forcible penetration by use of a foreign object. He was charged as an adult pursuant to Idaho Code section 20-509. Campbell ultimately pleaded guilty to amended charges: two counts of battery with attempt to commit rape, both against the same victim. The district court accepted Campbell’s pleas, and the State dismissed all remaining counts. In accordance with the plea agreement, both sides were free to argue at sentencing and nothing was binding on the court. In determining an appropriate sentence, the district court was permitted to consider not only the crimes perpetrated against the victim of the amended charges, but also the crimes alleged by the victims of the dismissed charges and of additional uncharged offenses. In all, Campbell had ten victims. The district court sentenced Campbell to a twenty-year determinate sentence on Count I and to a twenty-year indeterminate sentence on Count II, sentences to be served consecutively. Finding no reversible error, the Idaho Supreme Court affirmed Campbell's sentence. View "Idaho v. Campbell" on Justia Law

Defendant-appellant Desiree Karst appealed a district court’s partial denial of her motion to suppress evidence obtained during a traffic stop. Karst argued on appeal that the police sergeant impermissibly extended the traffic stop when he briefly interrupted his traffic-related investigation to contact dispatch and request a drug-dog unit at the scene. The Court of Appeals affirmed the district court’s decision, citing its recent decision in Idaho v. Still, 458 P.3d 220 (Ct. App. 2019). The Idaho Supreme Court granted Karst’s petition for review, overruled Still, reversed the district court’s decision, and remanded for further proceedings. The Supreme Court found that an unlawful extension of a traffic stop occurs when an officer’s detour prolongs, or adds time to, the original purpose for the stop. The Court of Appeals’ decision in Still improperly required “abandonment” of the traffic mission for a stop to become unlawfully extended. Here, the Court found the arresting sergeant indeed impermissibly extended the duration of the traffic stop when he requested the drug- dog unit, in violation of the Fourth Amendment. View "Idaho v. Karst" on Justia Law

Defendant Mark Wilson was charged with unlawful possession of a firearm in violation of Idaho Code section 18- 3316. The charge also carried with it a persistent violator sentencing enhancement. In a bifurcated trial, a jury first found Wilson guilty of unlawful possession of a firearm. The jury then found Wilson subject to an enhanced sentence due to his status as a persistent violator. Wilson appealed to the Idaho Court of Appeals, arguing that the State had failed to present sufficient evidence that he had been convicted of at least one previous felony at the time he possessed a firearm. Wilson also argued that the State failed to present sufficient evidence that he had been convicted of two prior felonies (an essential prerequisite of the persistent violator enhancement). The Court of Appeals affirmed Wilson’s convictions. Finding no reversible error, the Idaho Supreme Court affirmed Wilson’s convictions. View "Idaho v. Wilson" on Justia Law

Defendant-appellant Jennifer Olsen contended the application of withheld judgments in Idaho violated Idaho Code section 19-2601 because it caused criminal defendants to be convicted, thereby negating the legal benefits envisioned by the statute. Olsen was charged with misdemeanor driving under the influence, first offense. She entered into a plea agreement with the State, but later asked the magistrate court to not accept her guilty plea and grant her a “true” withheld judgment instead—i.e., one by which no conviction would take place . The magistrate court denied her motion, accepted her guilty plea, and granted her a withheld judgment. As part of the withheld judgment, the magistrate court: placed Olsen on supervised probation for 12 months subject to certain conditions, including: a requirement that she pay a fine and court costs; that her driving privileges be suspended for 180 days; that an interlock system be installed in her car; and that she attend Court Alcohol School and the Victim’s Impact Panel. Olsen appealed the magistrate court’s denial of her request for a “true” withheld judgment, and contented that court’s grant of a withheld judgment was not appropriately applied or effectuated. Finding no reversible error in the magistrate court’s judgment, the Idaho Supreme Court affirmed. View "Idaho v. Olsen" on Justia Law

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