Justia Idaho Supreme Court Opinion Summaries

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

Gregory Wade Towner, Sr., appealed his conviction for possession of methamphetamine. The arresting officer found the contraband on Towner’s person during a warrantless search. Towner moved to suppress, arguing that the officer’s conduct violated his constitutional rights against unreasonable search and seizure. The district court denied Towner’s motion after concluding that the officer’s seizure and subsequent search were a reasonable exercise of the officer’s community caretaking function. Towner appealed and the Idaho Court of Appeals affirmed. The Idaho Supreme Court granted Towner’s petition for review, and reversed, finding the trial court erred in concluding the officer's act of taking Towner into protective custody was within the officer’s authority under the community caretaker exception to the Fourth Amendment without considering the requirements of Idaho Code section 66-326(1). The case was remanded with instructions for the trial court to enter findings of fact related to whether the State proved that Towner was “gravely disabled” or an “imminent danger” to himself or others because of his mental illness under Idaho Code section 66-326(1), before he was taken into protective custody. View "Idaho v. Towner" on Justia Law

Defendant-appellant Vincent Brown made two oral requests for reduction of sentence prior to the district court relinquishing jurisdiction and imposing sentence. After sentence was imposed, Brown filed one written motion to reduce sentence pursuant to Idaho Criminal Rule 35(b). The district court denied the motion, and Brown appealed that denial. Before reaching the merits of Brown’s appeal, the Idaho Supreme Court addressed three prior decisions concerning Rule 35(b). The Court disavowed its decision in Idaho v. Wersland, 873 P.2d 144 (1994), and abrogated the holding in Idaho v. Bottens, 52 P.3d 875 (Ct. App. 2002) to the extent those cases treated the one motion limit in Rule 35(b) as jurisdictional in effect. The Court also clarified that the one motion limit in Rule 35(b) was a procedural rule, but the Court applied this announcement only prospectively. In addition, the Court abrogated Idaho v. Hurst, 258 P.3d 950 (Ct. App. 2011) where the Court of Appeals interpreted the one motion limit in Rule 35(b) as applying to both written and oral motions for a reduction of sentence at any point after a sentence is announced. Here, the Court affirmed the district court’s decision denying Brown’s Rule 35(b) motion to reduce his sentence: "Brown did not show that under any reasonable view of the facts, the district court’s sentence is excessive." View "Idaho v. Brown" on Justia Law

In 2006, Timothy Dunlap was sentenced to death by a Caribou County, Idaho jury for the death of a Soda Springs bank teller killed in 1991. In 2008, Dunlap filed a petition for post-conviction relief, alleging that numerous errors had occurred at his 2006 sentencing hearing. The district court dismissed the petition in its entirety. Dunlap appealed to the Supreme Court, which affirmed the dismissal of all but two of Dunlap’s claims: (1) multiple claims of prosecutorial misconduct under Brady v. Maryland, 373 U.S. 83 (1963) and Napue v. Illinois, 360 U.S. 264 (1959); and (2) ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984). Upon remand, the district court held two evidentiary hearings, one involving each of Dunlap’s remaining claims. The district court found that Dunlap had failed to establish either claim and denied Dunlap’s request for post-conviction relief. Dunlap timely appealed. Finding no reversible error in these decisions, the Idaho Supreme Court affirmed the district court. View "Dunlap v. Idaho" on Justia Law

Adam Paulson was arrested for misdemeanor driving under the influence (DUI) at the scene of the accident; he struck and killed a pedestrian with his vehicle as the pedestrian was crossing a road on a late November 2017 night. He was later charged with vehicular manslaughter, and a jury trial was held in October and November 2018. The jury convicted Paulson of vehicular manslaughter. Paulson appealed his conviction, arguing the district court erred when it refused to instruct the jury on the causation element required by Idaho Code section 18- 4006(3)(b). Paulson argued the district court should have instructed the jury regarding proximate, intervening, and superseding causes because the pedestrian, who was intoxicated, crossed the road in an unlit area with no marked crosswalk. Paulson also contended his right to a fair trial was violated when the district court instructed the jury using Idaho Criminal Jury Instruction (ICJI) 709, arguing that ICJI 709 did not set forth all the elements of Idaho Code section 18-4006(3)(b). After review, the Idaho Supreme Court found the district court erred in declining to instruct the jury on the required causal link between a defendant’s unlawful conduct and the victim’s death. The Court also found the district court erred in refusing to instruct the jury on whether the pedestrian’s conduct constituted an intervening, superseding cause and on a pedestrian’s duties when walking along roadways. The Supreme Court vacated Paulson's vehicular manslaughter conviction; the case was remanded for further proceedings. View "Idaho v. Paulson" on Justia Law