Justia Idaho Supreme Court Opinion Summaries

Defendant-appellant Corey McGrath was charged with two counts of lewd conduct with a minor: one regarding his five-year-old stepdaughter, B.B.; and one regarding his twelve-year-old stepdaughter, L.N. The two counts were severed for trial. During a jury trial on the first count, and over McGrath’s objection, the State introduced evidence of McGrath’s cell phone internet search history, which included searches for stepfather-stepdaughter themed pornography, along with two still images of pornographic videos purportedly viewed by McGrath. The jury convicted McGrath of one count of lewd conduct with respect to B.B. McGrath subsequently, pursuant to a plea agreement, pleaded guilty to felony injury to a child regarding L.N.’s accusations in the second count. McGrath was sentenced to life in prison with twenty years fixed for the lewd conduct charge, and ten years fixed for the felony injury to a child charge. The sentences were ordered to run concurrently. McGrath appealed his conviction of lewd conduct and the sentences imposed for both convictions. The Idaho Court of Appeals affirmed McGrath’s convictions and sentences. Finding no reversible error, the Idaho Supreme Court likewise affirmed McGrath's convictions and sentences. View "Idaho v. McGrath" on Justia Law

Defendant-appellant Danielle Guerra appealed a district court’s decision affirming a judgment of conviction for driving under the influence of drugs (“DUI”). Guerra contended the magistrate court erred when it denied her motion to set aside the jury verdict under Idaho Criminal Rule 29 or, in the alternative, grant a new trial under Idaho Criminal Rule 34. Further, Guerra argued the magistrate court erred when making a number of evidentiary rulings. The district court, acting in its appellate capacity, affirmed the magistrate court’s rulings and judgment of conviction. The Idaho Supreme Court found the district court erred when it upheld the magistrate court’s ruling permitting the arresting officer to testify about the motor vehicle warning on Guerra’s medication bottles. The pill bottles found in Guerra’s car were not offered or admitted into evidence. The officer testified to three warnings or “signs” on the medication bottles. The Court found that the inclusion of a warning on a medication bottle to “take due caution when operating a motor vehicle or heavy equipment” was more than just an admonishment: "The warning impliedly asserts that the medication in the bottle may impair the user’s ability to drive a car or use heavy equipment. Because this warning constitutes an assertion of fact that is capable of being proven true (i.e., the medication may impair the ability to drive), Officer DeLeon’s testimony concerning that warning constituted an assertion of fact and is subject to the hearsay rules." The Supreme Court concluded the State failed to carry its burden of demonstrating a proper non-hearsay purpose for the motor vehicle warning evidence. "The harmfulness of allowing Officer DeLeon’s testimony about the warning to come in for the truth of the matter asserted is evidenced in the statements of multiple jurors during voir dire in response to the prosecutor’s questions related to taking prescription medications while driving." Judgment was affirmed in part, reversed in part, and remanded the case to the district court with instructions to vacate the judgment of conviction and remand the case to the magistrate court for further proceedings. View "Idaho v. Guerra" on Justia Law

A grand jury indicted defendant-appellant Jordan Spencer for three counts of felony trafficking in heroin, one count of felony possession of methamphetamine, one count of felony possession of bath salts with intent to deliver, and one count of misdemeanor possession of drug paraphernalia. After a jury trial, Spencer was found guilty on all counts. Spencer appealed two of the six counts of which he was convicted, arguing there was insufficient evidence to sustain his conviction on one count of trafficking in heroin, and that the district court erred when it admitted the out-of-court statements of the State’s confidential informant because those statements violated his Sixth Amendment right to confront witnesses. The Idaho Supreme Court vacated Spencer's conviction on Count I, finding it was not supported by substantial evidence on which the jury could conclude the prosecution proved all essential elements beyond a reasonable doubt. The Court affirmed Spencer’s conviction of trafficking heroin as charged in Count II. View "Idaho v. Spencer" on Justia Law

Defendant-appellant was convicted by jury of domestic battery, attempted strangulation, and aggravated assault. He appealed to the Idaho Court of Appeals, which affirmed his convictions. Reyes petitioned for review by the Idaho Supreme Court, which was granted. On appeal, Reyes requested his convictions be vacated, arguing: (1) several evidentiary issues, including the admission of irrelevant and prejudicial evidence, rendered his trial unfair; (2) the district court abused its discretion when it found that the victim was unavailable to testify at trial under Idaho Rule of Evidence 804(a)(5) and allowed her preliminary hearing testimony to be read into the record; (3) the prosecutor’s closing argument impermissibly implied that the victim did not testify because she feared Reyes; and (4) these errors, when taken together, deprived him of his right to due process and a fair trial. After review, the Supreme Court found the district court erred when it determined the victim was unavailable to testify at trial, and allowed her preliminary hearing testimony to be read into the record. Further, the Court concurred the prosecutor's comment that the victim was "probably scared" to testify at trial was improper. In the aggregate, the Court concluded these errors rendered the trial unfair. Accordingly, Reyes' conviction was reversed and the case remanded for a new trial. View "Idaho v. Reyes" on Justia Law

A drug dog leapt into defendant-appellant Jacob Randall’s rental car during what was supposed to have been an exterior sniff. After the dog alerted to the presence of narcotics, officers searched the car and discovered 65 pounds of marijuana. Relying on an Idaho Court of Appeals case providing that a drug dog’s “instinctive” actions did not violate the Fourth Amendment, the district court denied Randall’s motion to suppress evidence of the marijuana because it found the dog’s entry was instinctive. The Idaho Supreme Court reversed, finding the rule articulated by the Court of Appeals and applied by the district court was inconsistent with the Fourth Amendment. View "Idaho v. Randall" on Justia Law

In March 2019, police officers stopped defendant-appellant Aaron Howard for a traffic violation and took him into custody after discovering an outstanding warrant for his arrest. Officers then brought in a drug-sniffing dog (“Pico”) to sniff the exterior of the car. Pico alerted to the presence of illegal drugs, and a subsequent search of the care uncovered methamphetamine, heroin and drug paraphernalia. Howard appealed the denial his motion to suppress the drug evidence, arguing the intrusion of the dog into the physical space of the car was a trespass, and therefore, an unlawful search under the common law trespassory test articulated in United States v. Jones, 565 U.S. 400 (2012). The Idaho Supreme Court agreed, reversed the denial of Howard’s motion to suppress, vacated his conviction, and remanded this case for further proceedings. View "Idaho v. Howard" on Justia Law

In December 2018, a Jack-in-the-Box employee suspected a “drunk driver” was in the restaurant’s drive-through line and reported this suspicion to law enforcement. An officer arrived on the scene and reported an odor of alcohol emanating from the passenger side of the vehicle, as well as empty alcohol containers on the floor near the vehicle’s passenger. The officer directed the driver, later identified as Andrew Wilson, to park the car. Wilson exited the vehicle. After noticing the odor of alcohol coming from Wilson, the officer began conducting field sobriety tests. The officer interpreted Wilson’s results as presenting signs of impairment. The officer then arrested Wilson for driving under the influence (DUI). A warrant for a blood draw was ultimately obtained after Wilson refused to submit to a breath test. The result of the blood draw conducted at the Pocatello Police Department reported a blood alcohol content of 0.192 percent. Wilson was charged with felony DUI based on two prior DUI convictions within the previous ten years. Wilson moved to suppress all evidence obtained as a result of his initial detention, arguing that the officer did not have reasonable suspicion to detain him in the restaurant parking lot. The district court granted Wilson’s motion and dismissed the charge against him with prejudice. The State appealed this decision to the Idaho Court of Appeals, which reversed the district court. The Idaho Supreme Court granted Wilson’s petition for review, and affirmed the district court’s decision to suppress because the State failed to preserve its argument for appeal. The Supreme Court found the State did not submit a responsive motion to Wilson's motion at the suppression hearing. "Allowing the State to argue on appeal that Officer Malone developed reasonable suspicion to detain Wilson prior to Wilson’s exit from the vehicle, when it implicitly conceded this point below, 'would sharply cut against our longstanding and recently re-affirmed policy of requiring parties to present their arguments to the court below[.]'" View "Idaho v. Wilson" on Justia Law

The State appealed a district court’s order granting Jennifer Warren’s (“Jennifer”) motion to suppress evidence. Boise Police Department Officer Matthew Lane stopped a GMC Yukon for a canceled and expired registration. The vehicle was driven by Steven Warren (“Steven”), and Jennifer was in the passenger seat. Steven told officers that Jennifer was his wife. Lane ran the identification information supplied by both parties, and the data system alerted there was a civil protection order and a criminal no-contact order in place preventing Steven from having contact with Jennifer. At this point, the officer abandoned the original purpose of the traffic stop in order to investigate whether Steven was in violation of either order by being with Jennifer in the car. To separate Jennifer from Steven, a second officer, Andrew Morlock, asked Jennifer to step out of the vehicle. Morlock asked Jennifer about some bulges in her pockets, and she pulled out a lighter, some money, and two syringes wrapped in tissue. Lane ran his drug-detection dog around the vehicle, and the dog alerted. A search of the car turned up a suspected marijuana joint and a tin holding small containers of a waxy substance, one of which later tested presumptively positive for marijuana. Jennifer’s purse was also in the vehicle and contained pills later identified as hydrocodone. During the car search, dispatch confirmed that the criminal no-contact order against Steven was active. Steven was taken into custody; Jennifer was arrested for possession of drug paraphernalia, and a subsequent search of her person revealed another syringe and a baggie of methamphetamine hidden in her bra. The State charged Jennifer with possession of methamphetamine, possession of hydrocodone, possession of marijuana, and possession of drug paraphernalia, as well as a persistent violator enhancement. The district court concluded the officers had no lawful basis to continue detaining Jennifer, a passenger in a vehicle, after officers abandoned the original purpose of the traffic stop in order to investigate whether the driver was in violation of a criminal no contact order barring him from being with Jennifer. On appeal, the State argued that reasonable suspicion a driver is engaged in criminal conduct not only allows officers to extend a traffic stop and detain the driver, but it also includes the continued lawful detention of all passengers. To this, the Idaho Supreme Court concurred and reversed the district court's suppression order. View "Idaho v. Warren" on Justia Law

Defendant-appellant Kelvin Alvarenga-Lopez appealed a district court’s denial of his motion to suppress. The State charged Alvarenga-Lopez with possession of methamphetamine and possession of drug paraphernalia. An officer observed a white Toyota Celica driving around 1 AM on the opposite side of the road. Because there was little traffic at that hour, the officer decided to conduct a “registration query,” through which he learned the car's registered owner was on probation. The officer followed the Celica as it made two more turns, then pulled over in front of a house. The officer pulled up behind the Celica, got out and walked to the driver's side door. The officer asked the driver, defendant, what he was doing in the area and where he was coming from. The house Alvarenga-Lopez parked in front of had a real estate sign and appeared to be empty. In addition, the registration query Officer Boardman conducted showed “there was no residence associated with that vehicle, [and] that the return didn’t come back to that location or anywhere near it.” The officer also described the circuitous route Alvarenga-Lopez took before parking as suspicious. After conducting his queries, the officer asked for and received verbal consent to search the Celica. During the search, the officer asked whether there was anything inside the care he needed to be aware of inside the vehicle. Alvarenga-Lopez responded that there was crystal meth in the center console. When the officer searched the center console he found a piece of clear cellophane with white crystalline substance he recognized as consistent with methamphetamine. Alvarenga-Lopez was then arrested. Alvarenga-Lopez argued he was unlawfully seized when an officer began questioning him at his car window. Thus, he claimed the evidence obtained during a subsequent search of the vehicle should have been suppressed as fruit of the unlawful seizure. The district court denied Alvarenga-Lopez’s motion to suppress after concluding the initial encounter was consensual. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Alvarenga-Lopez" on Justia Law

While the issue on appeal in this case centered on a conviction for violating a protection order, the principal focus was on the statutes and guidelines governing domestic violence courts in Idaho. Moawia Ahmed was charged with violating a protection order under Idaho Code section 39- 6312. At his arraignment, Ahmed’s case was transferred to the Domestic Violence Court (“DVC”). In his pretrial motions, Ahmed moved the magistrate court to dismiss the charge on constitutional grounds. The magistrate court denied Ahmed’s motion, the case proceeded to trial, and, ultimately, a jury found Ahmed guilty. Ahmed appealed his conviction to the district court. Ahmed maintained the magistrate court erred in denying his motion to dismiss. Ahmed also argued the magistrate court erred by: (1) admitting hearsay evidence; (2) failing to properly instruct the jury; and (3) requiring Ahmed to undergo a domestic violence assessment. The district court, in its intermediate appellate capacity, affirmed. Ahmed appealed the district court’s decision. Finding no reversible error, the Idaho Supreme Court affirmed the district court's decision. View "Idaho v. Ahmed" on Justia Law