Justia Idaho Supreme Court Opinion Summaries
Articles Posted in Idaho Supreme Court - Criminal
Idaho v. Sarbacher
The State charged Keith Sarbacher with grand theft by receiving or possessing stolen property: a 2001 Dodge pickup truck. After Sarbacher’s arrest, the State inventoried and photographed the truck and then returned it to the insurance company, who then sold the truck before Sarbacher’s attorneys could examine it. Sarbacher moved the district court for dismissal, arguing that the State violated his constitutional right to due process by disposing of evidence that was material and potentially exculpatory. The district court granted Sarbacher’s motion and dismissed the State’s case. The State appealed, arguing the evidence at issue was of unknown exculpatory value and the trial court expressly found that the State had not acted in bad faith. The Idaho Supreme Court concluded after a review of the district court record, it would have been entirely speculative for the district court to conclude that any of the additional analyses Sarbacher wanted to conduct would have resulted in the discovery of any exculpatory evidence to exonerate him. "the evidentiary value of the truck as the corpus delicti of the crime was sufficiently preserved by the State through its inventorying and photographing the vehicle prior to its release to Hunt’s insurance company." The Court vacated the district court's decision and remanded for further proceedings. View "Idaho v. Sarbacher" on Justia Law
Idaho v. Stegall
This case arose from a DUI suspect’s request to make a phone call from jail following his arrest. The State appealed a district court order granting Jeffery Stegall’s motion to suppress blood alcohol concentration (BAC) evidence obtained from a blood draw. The district court granted Stegall’s motion after determining that his right to due process had been violated when police officers at the jail refused his request to make a phone call. The State argued on appeal that the district court erred in determining Stegall’s due process rights were violated because the officers were not acting in bad faith when they failed to allow him access to a phone. To this, the Idaho Supreme Court disagreed, holding the district court did not err in determining the jail officers violated Stegall’s right to procedural due process when, despite his requests, they failed to allow him access to a phone for the purpose of contacting an attorney until the morning following his arrest. Accordingly, the district court’s order granting Stegall’s motion to suppress evidence of BAC was affirmed. View "Idaho v. Stegall" on Justia Law
Idaho v. Rebo
Jesse Rebo shared a home with his wife in Coeur d’Alene for ten years. Due to a domestic assault conviction, Rebo had been ordered by a judge to not go within 300 feet of his wife or the family residence. Even so, about a week after the court issued the order, Rebo was seen near his wife, outside the home, by a police officer. The officer announced herself and Rebo retreated inside. The officer entered the home and arrested Rebo. Methamphetamine was ultimately found on Rebo’s person when he was booked at the jail. Rebo brought a motion to suppress that evidence, which the district court denied. The court ruled that Rebo lacked standing to challenge the officer’s warrantless entry into his residence because society would not recognize Rebo’s subjective expectation of privacy in the residence from which a valid no contact order prohibited Rebo from entering. Rebo appealed, arguing that his ownership interest in the home allowed him to exclude others, including the officer from the home. Rebo also argued no exigent circumstances existed to justify the officer’s warrantless entry, and the evidence discovered after the officer’s unlawful entry should have been suppressed as “fruit of the poisonous tree.” Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Rebo" on Justia Law
Idaho v. Huckabay
Defendant John Huckabay appealed his criminal conviction of felony unlawful possession of a moose. A couple heard a gunshot as they were packing up to leave their cabin by Mica Bay on Lake Coeur d'Alene in October 2014. They encountered a large truck with a cow moose hoisted in the back on a metal frame. A man beside the truck introduced himself as John Huckabay. At their inquiry, Huckabay told the couple he had a tag for the moose. The driver, still in the truck, introduced himself as “Bob” later identified as Bob Cushman, a local butcher and the owner of the vehicle. As the couple departed, the wife looked up Idaho’s moose hunting season on her phone. Concerned of a potential hunting violation, the couple proceeded to the Idaho Department of Fish and Game’s (“IDFG”) regional office where they reported the shooting of an antlerless moose by a man named Huckabay. While Huckabay did not give the IDFG officers information about Cushman or details about who specifically shot the moose, Huckabay accompanied a third officer to the area where the moose had been killed. Officers obtained Cushman’s address and visited his residence. With Cushman’s permission, the officers checked inside a walk-in cooler on the premises and found a skinned and quartered cow moose, which lacked the requisite tag. The officers also noted that the carcass was still “very warm,” showing it had only recently been placed in Cushman’s cooler. A grand jury indicted Huckabay for felony unlawful killing or possession of a moose. Huckabay moved to dismiss his indictment, arguing the evidence was insufficient to establish probable cause and the indictment lacked essential elements of the crime. He also filed additional motions to challenge a lack of jurisdiction. Each of these issues hinged on his argument that the plain language of Idaho Code section 36-1404(c)(3) required more than one animal to warrant a felony charge. The district court denied Huckabay’s motions, finding that the indictment was sufficient to establish probable cause that Huckabay possessed the moose even if there was insufficient evidence to establish he killed the moose in question. The Idaho Supreme Court concurred with the district court that Idaho Code section 36-1401(c)(3) could plainly apply to the unlawful killing, possessing, or wasting of a single animal, and affirmed Huckabay's conviction. View "Idaho v. Huckabay" on Justia Law
Idaho v. Quigle
Robert Farrell-Quigle appealed his judgment of conviction for two counts of lewd conduct. He contends that the use of a shielding screen at trial during the testimonies of the alleged victims deprived him of his Fourteenth Amendment due process right to a fair trial, violated his Sixth Amendment right to confront the witnesses against him, and failed to comply with Idaho’s laws on alternative methods for child witness testimony. Leading up to trial, the State filed a motion seeking permission for both daughters to testify by alternative methods to avoid “increased emotional and mental trauma” from testifying in Farrell-Quigle’s presence. After review of the trial court record, the Idaho Supreme Court determined the use of the screen deprived Farrell-Quigle of his Fourteenth Amendment due process right to a fair trial, finding specifically that use of the screen was inherently prejudicial, and did not serve an essential state interest. "the district court’s decision to use the shielding screen instead of CCTV, which this Court had previously found does not result in inherent prejudice where necessity has been shown, was at its core a decision borne out of convenience. Convenience alone cannot outweigh a defendant’s constitutional rights. " Judgment was vacated and the matter was remanded for a new trial. View "Idaho v. Quigle" on Justia Law
Idaho v. Kent
The State appealed the district court’s order granting James Kent’s motion to suppress statements he made during a non-custodial interrogation. During this interrogation, the officer began reading Kent his Miranda rights, at which point Kent interrupted the officer and told him he would not answer any questions. The officer continued to read Kent his rights and, after completing the warnings, asked Kent if he was willing to speak with him. Kent said that he would, and eventually made incriminating statements. The district court suppressed the statements. The district court found that Kent was not in custody at the time, but nevertheless held: “Where Miranda warnings are read to an individual unnecessarily and the defendant invokes the right to remain silent, an officer may not ignore that invocation.” The State argued the district court erred by extending Miranda’s application to a non-custodial interrogation. In response, Kent contended that because he had a constitutional right to remain silent regardless of whether he was afforded Miranda warnings and irrespective of whether he was in custody, the district court did not err in suppressing his statements as having been obtained in violation of his right to remain silent. The Idaho Supreme Court determined the Kent made his statements voluntarily, therefore, the district court erred in suppressing the statements. Judgment was reversed and the matter remanded for further proceedings. View "Idaho v. Kent" on Justia Law
Idaho v. Doe
John Doe was a minor at the time the State alleged he committed two counts of lewd and lascivious conduct against a minor under the age of sixteen. Doe maintained his innocence, but argued that even if he did commit the acts alleged, the petition was time-barred under the four-year, catch-all limitation for civil actions found in Idaho Code section 5-224. The magistrate court (“juvenile court”) denied Doe's motion to dismiss the petition as untimely, and thereafter granted the State’s motion to waive Doe into adult proceedings. On intermediate appeal, the district court affirmed the decision of the juvenile court. The issue presented for the Idaho Supreme Court's review was whether proceedings under the Juvenile Corrections Act ("JCA") were "civil actions" subject to a civil statute of limitations. The Court concluded they were not, and affirmed the juvenile court, finding at JCA petition was not subject to the limitation in Idaho Code 5-224. View "Idaho v. Doe" on Justia Law
Idaho v. Loera
Justin Loera was convicted for battery on a correctional officer. Loera claimed the district court erred in three respects: (1) by partially quashing his subpoena duces tecum based on its relevance rather than the standards prescribed in Idaho Criminal Rule 17(b); (2) for ordering restitution without sufficient evidence; and (3) by failing to address his request for credit for time served. After review of the facts specific to this case, the Idaho Supreme Court affirmed the district court’s decision to partially quash Loera’s subpoena duces tecum. However, the Court vacated the district court’s order awarding restitution and remanded the case with instructions for the court to award Loera 202 days of credit for time served. View "Idaho v. Loera" on Justia Law
Idaho v. Winkler
Brandon Lynn Winkler appealed a district court order denying his motion to dismiss a January 2019 felony charge for driving under the influence of alcohol. Despite Winkler having been pardoned for a 2006 felony DUI, the district court determined that it still counted as a prior felony DUI for purposes of charging Winkler with a felony under Idaho Code section 18-8005(9). On appeal, Winkler argued the district court erred in concluding that a pardon did not prevent a prior felony DUI from being used to enhance a subsequent DUI charge to a felony under Idaho Code section 18-8005(9). The Idaho Supreme Court concurred: the district court erred in allowing Winkler's prior DUI conviction to be used to enhance his pending DUI charge. As such, the order was reversed and the matter remanded for further proceedings. View "Idaho v. Winkler" on Justia Law
Idaho v. Haws
Law enforcement used confidential informants to make several purchases of controlled substances from Darius Haws and his brother between April and May of 2015. While out on bond, Haws went to the residence of a female acquaintance. The woman called the police to report that Haws was trespassing. As a responding law enforcement officer approached Haws, the officer could “smell a strong odor of alcohol coming from [Haws’] breath.” When the officer attempted to arrest Haws, Haws resisted, swinging his arm and hitting the officer. Based on this altercation, the State charged Haws with battery on a police officer, resisting and obstructing an officer, criminal trespass, and disturbing the peace. Haws’ guilty pleas were entered pursuant to plea agreements in which he waived his right to appeal his convictions or sentences. The district court sentenced Haws to two years fixed, with four years indeterminate, for the delivery charge; and one year fixed, with three years indeterminate, for the battery charge. The sentences were ordered to run consecutively. Initially, the district court retained jurisdiction over Haws, but after performing poorly during the period of retained jurisdiction, the district court relinquished jurisdiction and ordered the original sentences be served. On appeal, Haws argued the district court abused its discretion in relinquishing jurisdiction and that his sentences were excessive. In response, the State sought to have Haws’ appeal dismissed because Haws expressly waived his right to appeal his sentences in the plea agreements he signed. The Court of Appeals agreed, dismissing Haws’ challenge to his sentences and affirming the district court’s decision to relinquish jurisdiction over Haws. On appeal to the Idaho Supreme Court, Haws contended the Court of Appeals incorrectly held that he had forfeited the right to address the validity of his plea agreements by not raising an issue of validity of those waivers in his opening brief. Instead, Haws contended it was the State’s obligation to assert the applicability of the appellate waiver, and that he should have had the opportunity to respond in his reply brief. Additionally, Haws argued his appellate waiver was not made knowingly, intelligently, and voluntarily because the district court made a statement that conflicted with the written plea agreements by noting that Haws had the right to appeal his sentences. The Supreme Court found no reversible error and affirmed the district and appellate courts. View "Idaho v. Haws" on Justia Law