Justia Idaho Supreme Court Opinion Summaries

Adam Bodenbach was convicted by jury for first-degree murder and possession of cocaine. On appeal, Bodenbach argued: (1) the district court’s “initial aggressor” jury instruction created reversible error because the instruction was unnecessary, confusing, and misstated Idaho law; and (2) the trial court erred in denying his motion to suppress statements he made shortly after the shooting during a police interview. To the latter contention, Bodenbach argued he did not knowingly and intelligently waive his Miranda rights because he was under the influence of drugs. In addition, Bodenbach argued the district court abused its discretion when it sentenced him. Finding no reversible error, the Idaho Supreme Court affirmed Bodenbach's convictions. View "Idaho v. Bodenbach" on Justia Law

Eric Livingston Weigle was found guilty by jury of robbing a credit union following a two-day trial. During the trial, the State’s forensic scientist used a PowerPoint presentation to explain how she matched one of Weigle’s known fingerprints to one found on the note used in the robbery. At trial, the presentation was admitted as an exhibit for demonstrative purposes without objection. It was then published to the jury. During its deliberations, the jury asked for a copy of the PowerPoint presentation. Weigle’s counsel objected; however, the district court overruled the objection and provided the jury with the presentation. The jury found Weigle guilty. Weigle appealed his judgment of conviction. The Court of Appeals affirmed. To the Idaho Supreme Court, Weigle argued that giving the presentation to the jury during deliberations was improper and constituted reversible error. Finding no abuse of discretion in allowing the jury to see the presentation, the Supreme Court affirmed. View "Idaho v. Weigle" on Justia Law

Jersson Neftaly Roque Medina (Medina) was convicted by jury of trafficking heroin and conspiracy to violate the Uniform Controlled Substances Act. The charges were brought through two separate cases that arose out of the same set of facts; the cases were consolidated and tried together. Medina appealed his convictions, arguing: (1) fundamental error occurred when he appeared before the jury in chains; (2) fundamental error occurred when the jury instruction listing possible overt acts made in the furtherance of the conspiracy listed numerous acts that did not constitute a proper basis for him to have been found guilty; and (3) there was insufficient evidence to establish the agreement element of the conspiracy charge. Finding no reversible error, the Idaho Supreme Court affirmed Medina's conviction. View "Idaho v. Medina" on Justia Law

Chad Schiermeier was convicted by jury of grand theft. DARE/PAL was a non-profit organized “to foster, promote, encourage and increase the knowledge, and understanding of alcohol and drug addictions or related problems.” To further its purpose, DARE/PAL offered outdoor-related group activities during the summer months to children between the ages of nine and sixteen. Some of the activities included hiking, golfing, fishing, rafting, and attending baseball games. The activities were primarily funded by the Blaine County Idaho Sheriff’s Office through drug forfeiture funds and by local philanthropists through donations and grants. Schiermeier was a deputy sheriff for the Blaine County Sheriff’s Office from 1999 to 2015, serving as a middle school resource officer and the director of DARE/PAL; he was appointed as manager of the program in 2002. Following Schiermeier’s appointment as manager, the board slowly became inactive, neglecting its duties and entrusting Schiermeier to handle all things related to DARE/PAL. In July 2015, a charitable group called 100 Men Who Care donated approximately $5,100 to DARE/PAL. Shortly thereafter, the group followed up with Schiermeier’s supervisor, Lieutenant Carpita, to see how their donation had been spent. Carpita in turn asked Schiermeier. Several months went by with vague responses, if any, from Schiermeier. Finally, in November 2015, after more than three months of requests and meetings, Schiermeier provided Carpita with the requested DARE/PAL bank records. After reviewing the records, Carpita became suspicious after he noticed “a lot of cash withdrawals through the ATM . . . during times when the PAL activities were not going on.” Consequently, Carpita decided to have the matter independently investigated by the Idaho State Police. The bank records revealed that from 2009 to 2015, Schiermeier made several extravagant purchases of high-end outdoor equipment and clothing. Following the independent investigation by the Idaho State Police, the State charged Schiermeier with one count of grand theft. Schiermeier appealed his judgment of conviction, arguing the State did not prove the elements of grand theft beyond a reasonable doubt. Schiermeier also argued the district court abused its discretion by imposing an excessive sentence. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Schiermeier" on Justia Law

Aaron Lantis was charged with the misdemeanor offense of disturbing the peace in violation of Idaho Code section 18-6409. The State alleged he committed the crime by sending sexually suggestive photographs of H.H. (Lantis’ ex-girlfriend) to her employer in an unsuccessful attempt to have her fired During trial, Lantis moved for a judgment of acquittal asserting that the statute did not apply to his actions. The magistrate court denied Lantis’ motion. Lantis was found guilty by a jury and he made the same motion post-verdict, which was likewise denied. He appealed to the district court, asserting the same grounds. The district court agreed with Lantis and vacated Lantis’ conviction, holding that Lantis’ conduct was outside the scope of the statute. The State appealed; the Idaho Supreme Court affirmed the district court. View "Idaho v. Lantis" on Justia Law

In 2009, a jury convicted Vance Thumm of aggravated battery or aiding and abetting aggravated battery and of being a persistent violator of the law. Thumm pursued a direct appeal, but was unsuccessful. In 2013, through counsel, Thumm petitioned for post-conviction relief. The State responded by filing a motion for summary disposition. The district court eventually granted the State’s motion and dismissed the post-conviction petition. Thumm appealed to the Idaho Supreme Court, alleging: (1) ineffective assistance of counsel at trial, sentencing, and on appeal; (2) a Brady violation; (3) prosecutorial misconduct; and (4) cumulative error. Finding no reversible error, the Supreme Court affirmed the district court’s grant of summary disposition. View "Thumm v. Idaho" on Justia Law

The State appealed a district court order granting Monica Wolfe’s motion to suppress evidence obtained from a cell phone in her possession.In early 2017, a dog owned by Robert Wolfe and his new wife became unusually lethargic and eventually died. Around that same time, they noticed golf balls in their yard, some of which had been chewed. Because no one in the family played golf and they did not live near a golf course, suspicion arose. As a result, the family initiated an investigation through Animal Control and discovered that the golf balls appeared to have antifreeze residue on them. A veterinarian later confirmed that the dog died due to ingesting antifreeze and golf balls. From this, the family suspected that the dog had been poisoned. Soon after the dog died, Daniel Collins, a man who had dated Robert’s ex-wife, defendant Monica Wolfe, contacted Robert and informed him that he had been solicited by Wolfe to kill Robert and his dog. Robert met with Collins at a restaurant and, unbeknownst to Collins, recorded their conversation. During the conversation, Collins stated that Wolfe asked him to find out when Robert left work so that he could “take [him] out from there.” Regarding the dog, Collins said that he was hoping he could “get to [Robert]” before it died, and that Wolfe’s plan was to mix car antifreeze with meatballs to kill the dog. He further asserted that Wolfe “was asking [him] for help . . . but basically wanted to be the one to have [Robert] underground” because “she [was] angry” with him for obtaining custody of their two kids. After this conversation, Robert contacted the police to report Wolfe and Collins. Wolfe was later interviewed. She also admitted to having a conversation about killing a neighbor’s dog with antifreeze, but denied killing Robert’s dog. Further, she and the detective discussed text messages that were on a cell phone in her possession. The district court held that law enforcement unlawfully seized the phone prior to obtaining a warrant to search it. The State argued the "independent source exception" applied because law enforcement subsequently obtained a valid search warrant that was not tainted by the unlawful seizure, and therefore, the evidence found on the phone should not have been suppressed. The Idaho Supreme Court disagreed and affirmed the district court. View "Idaho v. Wolfe" on Justia Law

Christopher Shanahan appealed a district court decision denying his motion to correct an allegedly illegal sentence imposed in 1997. In the Fall of 1995, Shanahan and two friends devised a scheme to rob a convenience store in Grant, Idaho, and use the money to travel to Las Vegas, Nevada. Once there, they planned to join a gang and lead a life of crime. Shanahan argued his indeterminate life sentence, with the first thirty-five years fixed, for the murder he committed as a juvenile in 1995 was equivalent to a life sentence without the possibility of parole. Therefore, he argued that under Miller v. Alabama, 567 U.S. 460 (2012) and persuasive precedent from other states, he was entitled to a new sentencing where his youth and its attendant characteristics could be properly considered. Otherwise, he argued, his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The district court denied the motion on the basis that Miller was inapplicable to Shanahan’s sentence and, even if it applied, the sentencing court heard testimony regarding his age and mental health prior to sentencing him. Finding no reversible error, the Idaho Supreme Court affirmed Shanahan's conviction. View "Idaho v. Shanahan" on Justia Law

Samantha Cook was pulled over by a police officer after the officer noticed her vehicle lacked both front and rear license plates. As the vehicles slowed to pull over, the officer noticed a piece of paper in the rear window of Cook’s car. Upon approaching the pulled-over vehicle, the officer noticed that the piece of paper was a temporary registration permit, which was unreadable due to condensation from rain earlier in the evening. The officer then spoke with Cook, detected the smell of marijuana, searched her vehicle, located controlled substances, and arrested her. Cook filed a motion to suppress the evidence obtained during the stop on the grounds that the officer lacked probable cause to stop her vehicle. The district court denied Cook’s motion. The district court found, based on Idaho v. Kinch, 356 P.3d 389 (Ct. App. 2015), a reasonable suspicion existed that Cook had violated Idaho Code section 49-432(4), which required a driver to display a permit “upon the windshield of each vehicle or in another prominent place where it may be readily legible.” As a result, the district court found the seizure legal and the evidence obtained after the seizure properly obtained. The Court of Appeals affirmed. Cook argued on appeal, among other things, that the district court erred in denying her motion to suppress because Idaho Code section 49-432(4) was unconstitutionally vague as applied to her conduct. The Idaho Supreme Court concurred, concluding the statute was unconstitutionally vague. The Court reversed the district court’s denial of Cook’s motion to suppress; Cook’s conviction was vacated, and the matter remanded for further proceedings. View "Idaho v. Cook" on Justia Law

Defendant Shawn Coats was charged with eight different offenses after he took an elderly man’s debit card and deposited fraudulent checks into the man’s credit union account to create funds for a multi-day shopping spree at Walmart. After a jury trial, he was convicted of seven of the offenses, including grand theft of retail goods and fraudulent use of a financial transaction card. On appeal, Coats contended the jury did not have substantial evidence to convict him of grand theft of retail goods from an owner because Walmart was paid in full for the goods, and Morgan, the man from whom he obtained the debit card, never owned the purchases. Alternatively, he argued he was subjected to double jeopardy upon being convicted for both grand theft and fraudulent use of a financial transaction card, because fraudulent use was a lesser included offense of grand theft. The Idaho Supreme Court determined there was not substantial evidence for the conviction of grand theft: "While Idaho’s theft statute is broad and covers many misdeeds, there must be a careful analysis of what was stolen and from whom before a charging decision is made and the jury is instructed." Because this case was remanded to the district court with instructions to vacate Coats’s conviction on grand theft, the Supreme Court did not reach the merits of Coats’s double jeopardy argument. "[I]f the State desired to charge Coats for grand theft relating to the purchases made at Walmart with a debit card, it had to properly allege Coats wrongfully obtained money from the credit union that credited Morgan’s account with funds for the POS transaction. Yet, the State charged Coats with wrongfully obtaining retail goods from an owner—there was not sufficient evidence presented for a jury to convict Coats of this specific crime." View "Idaho v. Coats" on Justia Law