Justia Idaho Supreme Court Opinion Summaries

Over a period of several months, William Dix bought several thousand dollars’ worth of goods from Grainger Supply on credit. On the same days he bought the goods, he pawned them. Dix was charged with grand theft and burglary, and pleaded not guilty to both counts. At trial, the State argued that Dix committed theft by obtaining the goods on credit without intending to pay for them, and committed burglary by receiving loans from the pawn shop in exchange for the goods based on false representations that he owned them. After the close of the State’s case-in-chief, Dix moved for a judgment of acquittal under Idaho Criminal Rule 29 on both charges, arguing that under Idaho v. Bennett, 246 P.3d 387 (2010), he became the owner of the goods once he obtained possession of them from Grainger, and as the owner, he could lawfully pawn them. The district court denied Dix’s motion, and the jury subsequently returned guilty verdicts on both counts. After trial, Dix renewed his Rule 29 motion on the burglary charge, and this motion was also denied. The district court entered an order withholding judgment and placing Dix on probation for eight years. Dix timely appealed, and the Court of Appeals affirmed. Upon certiorari review, the Idaho Supreme Court reversed Dix’s convictions and remanded the case to the district court with instructions to enter a judgment of acquittal on both counts. View "Idaho v. Dix" on Justia Law

John Rodriguez sold a firearm to an individual who had visible gang tattoos and had previously identified himself as a member of the Norteno gang, but who was actually an informant paid by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The State charged Rodriguez with two counts of providing firearms to criminal gang members under Idaho Code section 18-8505 and a sentencing enhancement for providing the firearm to further criminal gang purposes under Idaho Code section 18-8503(1)(b). After trial, the jury returned a verdict of guilty as to Count I but not guilty as to Count II and answered "no" to the sentencing enhancement question. The district court suspended a unified sentence of ten years and placed Rodriguez on probation for ten years. Rodriguez appealed, arguing his conviction should have been vacated because criminalizing the sale or transfer of firearms to gang members without the intent to further gang activity, Idaho Code section 18-8505 violated rights guaranteed by the federal Constitution: the freedom of association under the First Amendment, the right to bear arms under the Second Amendment, and the due process requirement of personal guilt under the Fourteenth Amendment. Finding that Rodriguez forfeited his constitutional challenges by failing to present them to the trial court, the Idaho Supreme Court affirmed. View "Idaho v. Rodriguez" on Justia Law

Steven Chambers appealed his conviction entered upon his "Alford" plea to battery with intent to commit a serious felony. Chambers was initially charged with forcible rape against a young woman. Pursuant to I.R.E. 412, Chambers moved to introduce evidence of a purportedly false allegation "N.S." made against a different individual approximately six months after her alleged rape by Chambers. The State objected to the admission of such evidence. After a Rule 412 hearing, the district court excluded evidence of the purportedly false allegation. The Idaho Court of Appeals heard Chambers’ appeal and held that false allegations made after the charged conduct could be admissible. However, the appellate court concluded that Chambers had failed to prove falsity at the Rule 412 hearing. After its review, the Idaho Supreme Court concluded the district court erred when it determined that Rule 412 contained a temporal requirement that the false allegation must precede the events giving rise to the charge. Further, the district court abused its discretion by applying the wrong balancing test. The Supreme Court announced guidelines and procedure for the district court to use on remand to determine whether evidence of the purportedly false allegation was admissible. Judgment of conviction was vacated and the matter remanded for further proceedings. View "Idaho v. Chambers" on Justia Law

Britain Lee Barr pleaded guilty to five counts of sexual exploitation of a child and to being a repeat sex offender. The district court sentenced Barr to five, fifteen-year fixed sentences, to run consecutively to each other, for an aggregate determinate term of seventy-five years, reasoning that section 19-2520G left it no discretion to sentence Barr to anything less severe. On appeal Barr argued the district court abused its discretion when it failed to perceive that it had discretion to: (1) designate indeterminate and determinate portions of the mandatory fifteen-year sentences; and (2) run the sentences concurrently with one another rather than consecutively. Barr also claimed that if the legislature intended section 19-2520G to deprive the court of its traditional power to decide whether to run sentences consecutively or concurrently, the statute is unconstitutional. The Idaho Supreme Court determined Barr’s arguments were not properly preserved for appeal. Therefore, the Court affirmed his conviction and sentence. View "Idaho v. Barr" on Justia Law

David Glodowski appealed after he was convicted for failing to update his sex-offender registration in violation of Idaho Code section 18-8309. He argued the district court erred by ruling that his prior conviction under a Wisconsin statute was “substantially equivalent” to Idaho statutes that required sex-offender registration in Idaho. After review, the Idaho Supreme Court determined the district court improperly allowed the State to seek a redetermination of the “substantially equivalent” element given that the Idaho Bureau of Criminal Identification made a final determination on that element. However, because the State put forth sufficient evidence to prove that element, and the district court’s jury instruction accomplished the same purpose, the Supreme Court concluded the error was harmless. Accordingly, the Court found no reversible error in the district court’s decision to grant the State’s motion and provide the jury instruction. Therefore, judgment of conviction was affirmed. View "Idaho v. Glodowski" on Justia Law

Nicholas Blythe appealed after he was convicted of possessing a controlled substance. He conditionally pled guilty, reserving the right to challenge his sentence. On appeal, he argued the district court erred in denying his motion to suppress certain evidence found because the evidence presented at trial was found in violation of Blythe's Fourth Amendment rights. After review, the Idaho Supreme Court determined the search at issue took place before an arrest occurred, and because no rationale justifying a search incident to arrest was sufficiently present here, the search of Blythe’s shoes was not a valid search incident to arrest. Therefore, the district court erred in holding that the search was reasonable under the Fourth Amendment. Blythe's conviction was vacated, the district court order denying Blythe's motion to suppress was reversed, and the matter remanded for further proceedings. View "Idaho v. Blythe" on Justia Law

Timothy Jones was convicted by jury of trafficking heroin and possession of drug paraphernalia. On appeal, he argued the trial court erred in admitting certain evidence regarding his probation status, a knife found in the initial police search of his person, and that the trial court abused its discretion in arriving at his sentence. Finding no reversible error, the Idaho Supreme Court affirmed Jones' conviction and sentence. View "Idaho v. Jones" on Justia Law

Richard Hess appealed an order of restitution entered against him following his guilty plea to trafficking heroin. Hess relied on the Idaho Supreme Court’s decision in Idaho v. Nelson, 390 P.3d 418 (2017), to argue that there was insufficient evidence to support all but $1,500 of the award. The Court of Appeals reversed the restitution order, and the Supreme Court granted the State’s timely petition for review. The Court determined that $500 of the district court’s award of investigation costs was unsupported by the evidence. However, the district court correctly awarded the remaining amounts of restitution because: (1) Hess failed to preserve his foundational objections; and (2) substantial evidence supported the remainder of the award. View "Idaho v. Hess" on Justia Law

Jesus Manuel Garcia was found guilty by jury of second-degree murder, aggravated battery, use of a deadly weapon during the commission of the former crimes, and possession of a controlled substance. The district court sentenced Garcia to an indeterminate life sentence with twenty-five years fixed for second degree murder, which included a sentencing enhancement for the use of a deadly weapon. The district court also sentenced Garcia to twenty years, with six years fixed, for aggravated battery; this also included a sentencing enhancement for the use of a deadly weapon. The district court further sentenced Garcia to three years fixed for the possession of a controlled substance conviction. All three sentences were ordered to run concurrently. In addition, the district court ordered restitution to the victims in the amount of $162,285.27. Garcia timely appealed, arguing: (1) the district court abused its discretion in allowing the State to present “in-life” photos of the victim and to elicit testimony about the victim’s personality and character during trial; (2) the prosecutor committed misconduct when she referred to this challenged evidence in her closing statement; (3) Garcia was deprived of due process because of the cumulative errors; (4) the district court abused its discretion in imposing a sentence that did not give proper weight and consideration to mitigating factors; and (5) the district court abused its discretion in ordering Garcia to pay restitution without adequately considering his current and future ability to pay restitution. Finding only that the district court abused its discretion in ordering restitution without proper consideration of Garcia's ability to repay the amount in the future, the Idaho Supreme Court affirmed conviction, vacated the restitution order, and remanded for reconsideration of Garcia's foreseeable ability to pay restitution. View "Idaho v. Garcia" on Justia Law

Prior to sentencing, defendant James Burke was committed to the state mental hospital for 56 days to restore him to competency. After being evaluated and deemed competent to proceed to trial, Burke was returned to the county jail and later pleaded guilty pursuant to a plea agreement. At the conclusion of his sentencing hearing, Burke sought credit for the 56 days of time spent in court-ordered commitment. The district court denied the motion, concluding that commitment to a state mental hospital did not fall under the definition of ‘incarceration’ in Idaho Code section 18-309. After reviewing this issue carefully, the Idaho Supreme Court disagreed with the district court’s "thorough and thoughtful analysis," holding that court-ordered commitment to state custody pursuant to Idaho Code sections 18-210 and 18-211 met the functional and legal definition of “incarceration” under Idaho Code section 18-309. "The extent of the liberty interests restricted by Burke’s court-ordered commitment to State Hospital North are just too similar to imprisonment to conclude otherwise." Accordingly, the Court reversed the district court’s order denying Burke’s request for credit for time served and remanded the case for the district court to enter an order crediting him with the fifty-six days he spent committed to State Hospital North while the State restored his competency to face criminal charges. View "Idaho v. Burke" on Justia Law