Justia Idaho Supreme Court Opinion Summaries

Lea Anne Eaton was arrested and charged with felony burglary under Idaho Code section 18-1401 for using discarded Walmart receipts to return stolen items for a refund. Shortly after her charge, a new statute, Idaho Code section 18-1401A, creating a misdemeanor offense of "commercial burglary," became effective. Eaton filed a motion to reduce her felony charge to the new misdemeanor charge, which the district court denied. Eaton entered a conditional guilty plea, reserving her right to appeal the denied motion, and was sentenced to a unified ten-year sentence with four years fixed. She subsequently filed motions for reconsideration and to correct an illegal sentence, both of which were denied. Eaton appealed these decisions.The Idaho Court of Appeals upheld Eaton's conviction and sentence. Eaton then filed a Petition for Review, which the Idaho Supreme Court granted. The Supreme Court reviewed whether the district court erred in denying Eaton's motion to reduce her charge and her motion to correct an illegal sentence.The Idaho Supreme Court held that the commercial burglary statute, Idaho Code section 18-1401A, was not retroactive and did not apply to Eaton's conduct, which occurred before the statute's enactment. The Court found that the statute created a new offense with distinct elements from the general burglary statute and did not amend the penalties for general burglary. Therefore, Eaton was properly charged and convicted under the general burglary statute, Idaho Code section 18-1401. The Court also held that Eaton's sentence was not illegal, as she was not entitled to the lesser penalty under the commercial burglary statute. Consequently, the Idaho Supreme Court affirmed the district court's judgment and the denial of Eaton's Rule 35(a) motion. View "State v. Eaton" on Justia Law

In April 2021, a confidential informant (CI) working for the Blaine County Sheriff’s Office was introduced to Kelly D. Webb. The CI, at the request of the Sheriff’s Office, attempted to purchase methamphetamine from Webb. Webb sold the CI more than 28 grams of methamphetamine on two occasions, leading to his indictment by a grand jury for two counts of felony trafficking in methamphetamine. Webb pleaded not guilty and filed a motion in limine to present a defense of "charge entrapment," arguing that he was induced by law enforcement to sell a larger quantity of drugs than he intended. The district court denied his motion, and Webb entered a conditional guilty plea, reserving his right to appeal the denial.The District Court of the Fifth Judicial District of Idaho reviewed Webb's motion and held hearings on the matter. The court determined it had the authority to recognize charge entrapment as an extension of the common law defense of entrapment but ultimately declined to do so. The court noted that charge entrapment is a minority position in other jurisdictions and is typically associated with the Federal Sentencing Guidelines, which differ from Idaho’s mandatory minimum sentencing laws. Webb was sentenced to a unified sentence of 7 years, with 3 years fixed, and a $10,000 fine, which are the mandatory minimums for trafficking in methamphetamine.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's decision. The court declined to recognize the defense of charge entrapment, noting that Idaho’s traditional entrapment defense is intended to protect innocent individuals from being induced to commit crimes, which did not apply to Webb’s case. The court also found that the rationale behind charge entrapment in federal cases, which is based on the Federal Sentencing Guidelines, does not apply to Idaho’s mandatory minimum sentencing scheme. Therefore, the court upheld the district court's denial of Webb's motion in limine. View "State v. Webb" on Justia Law

In this case, the paternal grandmother, Natasha Ray, was appointed as the temporary guardian of a minor child shortly after the child's birth in 2015, with the father's consent. Over the next five years, the child's parents, Anthony Lowman and Kayla Morgan-Smart, contested the temporary guardianship. The magistrate court found no grounds to grant a permanent guardianship to the grandmother and aimed to reunify the child with the parents through a phased visitation plan. Despite this, the grandmother was held in contempt multiple times for failing to comply with court orders regarding visitation.The grandmother appealed the magistrate court's decisions to the district court. However, neither she nor her attorney, Wm. Breck Seiniger, filed the required opening briefs. The district court dismissed the appeal due to the failure to file timely briefs and found no good cause for the delay. The grandmother then filed a new notice of appeal from a subsequent contempt judgment, but again failed to file the necessary briefs on time, leading to the dismissal of the second appeal as well.The Supreme Court of Idaho reviewed the case and determined that Seiniger did not have the authority to represent the child, as he was never appointed by the magistrate court. The court also noted that the grandmother failed to challenge the district court's dismissal of her appeals in her briefing. Consequently, the Supreme Court affirmed the district court's decisions to dismiss the appeals and struck Seiniger's petition to intervene and notices of joinder. View "Ray v. Morgan-Smart" on Justia Law

A child was born to Anthony Lowman and Kayla Morgan-Smart in 2015. The child's paternal grandmother, Natasha Ray, was appointed as her temporary guardian shortly after birth. Ray was later allowed to intervene in the parents' divorce action to determine custody once the guardianship ended in August 2021. Before the guardianship ended, attorney Wm. Breck Seiniger, Jr. was asked by Ray to represent the child, which he accepted without court appointment. Seiniger filed a notice of appearance in the divorce action, which the parents objected to. The magistrate court ruled that Seiniger could not represent the child as there was no motion to appoint counsel, it was unnecessary at that stage, and a neutral attorney would be appointed if needed.The parents reached a custody agreement and filed a stipulation for joint custody. Despite the magistrate court's ruling, Seiniger objected to the proposed judgment on behalf of the child. The magistrate court overruled the objections and entered a judgment consistent with the parents' stipulation. Ray appealed the custody judgment to the district court, joined by Seiniger. The district court concluded that Seiniger had no authority to represent the child and dismissed the appeal, characterizing Seiniger as an "officious interloper." Ray's appeal was later dismissed for failure to provide timely briefing.The Supreme Court of Idaho reviewed the case and affirmed the district court's decision. The court held that the magistrate court acted within its discretion in rejecting Seiniger's representation of the child, as there was no motion to appoint counsel and it was unnecessary at that stage. The court also found that Seiniger's arguments were unpreserved and unsupported by sufficient authority. Consequently, the district court's order, including the decision to strike all pleadings filed by Seiniger, was affirmed. View "Lowman v. Morgan-Smart" on Justia Law

Dan Lee Gearhart and Kristin A. Marlar divorced in September 2018, with Gearhart ordered to pay monthly child support. Gearhart applied for Social Security Disability Insurance (SSDI) benefits for himself and his children, which were approved after the divorce, with payments retroactive to August 2018. The children’s benefits were paid to Marlar as their representative payee. Gearhart stopped making child support payments, believing the SSDI payments covered his obligation. In May 2022, Gearhart petitioned the magistrate court to credit the SSDI payments against his child support arrearage, effectively reducing it to $0.00. Marlar opposed this, arguing it constituted a retroactive modification of child support.The magistrate court credited the SSDI payments against Gearhart’s arrearage, eliminating his outstanding balance. Marlar appealed to the district court, which reversed the magistrate court’s decision, concluding that Idaho Code section 32-709 prohibited retroactive modification of child support. The district court remanded the case with instructions to deny the application of SSDI payments as a credit against Gearhart’s arrearage.The Supreme Court of Idaho reviewed the case and reversed the district court’s decision. The Supreme Court held that Idaho Code section 32-709 did not apply to Gearhart’s petition because he was not seeking a modification of his child support obligation but rather a credit for SSDI payments already made. The court concluded that section 32-709(2) did not limit the magistrate court’s discretion to credit SSDI benefits against the child support arrearage. The case was remanded to the district court with instructions to reinstate the magistrate court’s judgment crediting the SSDI payments against Gearhart’s arrearage. Neither party was awarded attorney fees on appeal. View "Marlar v. Gearhart" on Justia Law

Kadence Dawn Marble was a passenger in a vehicle stopped for speeding in Bonner County, Idaho. During the stop, the officer detected the smell of marijuana and found marijuana and drug paraphernalia in the vehicle. Marble admitted to knowing about the marijuana. She was charged with violating Idaho’s “frequenting” law, which makes it a misdemeanor to be present at a place where illegal controlled substances are held for distribution or use. Marble filed a motion to dismiss, arguing that a moving vehicle is not a “place” under the statute. The magistrate court agreed and dismissed the case.The State appealed to the District Court of the First Judicial District, which reversed the magistrate court’s decision. The district court concluded that Marble’s motion to dismiss was procedurally improper and that the question of whether a moving vehicle could be considered a “place” was a factual issue to be resolved at trial. Marble then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho reversed the district court’s decision, holding that the district court erred in failing to rule on the merits of the State’s appeal. The Supreme Court determined that whether a moving vehicle constitutes a “place” under Idaho Code section 37-2732(d) is a question of law, not fact. The Court held that a moving vehicle can be considered a “place” where illegal controlled substances are present. Additionally, the Court found that the statute is not unconstitutionally vague as applied to Marble’s conduct. The case was remanded to the district court with instructions to remand it to the magistrate court for a trial on the merits. View "State v. Marble" on Justia Law

Josina Marie Regan was convicted of three counts of conspiracy related to possession of methamphetamine, grand theft, and possession of bath salts. The charges stemmed from an incident where Regan shot and killed her boyfriend, John Baker, and subsequently removed various items, including drugs and cash, from his residence with the help of Todd Potter and Robert Glenn. These items were later found in a motel room rented by Regan.The District Court of the Fourth Judicial District of Idaho provided jury instructions that included the term "and/or" between Regan's name and the names of the alleged co-conspirators. Regan appealed, arguing that these instructions were fundamentally erroneous as they allowed the jury to convict her without finding that she was a party to the agreement beyond a reasonable doubt. The Idaho Court of Appeals affirmed the district court's decision, holding that the instructions were not erroneous and that the evidence was properly admitted.The Supreme Court of Idaho reviewed the case and agreed with Regan, finding that the district court's jury instructions were indeed erroneous. The instructions misled the jury by not requiring them to find that Regan was a party to the agreement, thus relieving the State of its burden to prove this essential element beyond a reasonable doubt. The Supreme Court held that this error was clear from the record and was not harmless, as it affected the outcome of the trial. Consequently, the Supreme Court vacated Regan's conspiracy convictions. View "State v. Regan" on Justia Law

In October 2021, Gregg Alan Hoover was arrested and cited for misdemeanor domestic battery. In April 2022, the State amended the charge to a felony under Idaho Code section 18-918(5), citing Hoover’s March 2022 conviction for felony domestic battery with traumatic injury. Hoover moved to dismiss the felony enhancement, arguing that the March 2022 conviction occurred after the October 2021 incident. The district court agreed and dismissed the felony enhancement, reasoning that the enhancement could not apply because the conduct in question occurred before the March 2022 conviction.The State appealed, arguing that the enhancement provision only requires a prior felony conviction within fifteen years of the subsequent conviction, not that the criminal conduct must occur after the prior conviction. The Idaho Court of Appeals issued an unpublished decision, and Hoover petitioned for review, which the Idaho Supreme Court granted.The Idaho Supreme Court reviewed the case de novo and concluded that the plain language of Idaho Code section 18-918(5) does not impose a timing requirement related to the criminal conduct. The statute enhances a charge if a defendant has a prior felony conviction and is found guilty of a further violation within fifteen years, regardless of when the conduct occurred. The Court reversed the district court’s dismissal of the felony enhancement and remanded the case for further proceedings. View "State v. Hoover" on Justia Law

In 2019, Colby James Bray died while in the custody of the Idaho Department of Juvenile Corrections (IDJC). His parents, Jeffrey and Michelle Bray, acting as personal representatives of his estate, filed a wrongful death suit in federal court one day before the two-year statute of limitations expired. They later voluntarily dismissed the federal case and refiled in state court nearly three years after Colby's death. The defendants moved for summary judgment, arguing the claims were time-barred by the two-year statute of limitations. The district court granted the motions and dismissed the complaint with prejudice.The Brays appealed, arguing that Idaho Code section 5-234 and 28 U.S.C. section 1367(d) tolled the statute of limitations. The district court had concluded that section 5-234 did not toll the time for filing the state complaint and that section 1367(d) did not apply to IDJC due to Eleventh Amendment immunity. The court also awarded costs and attorney fees to the defendants.The Supreme Court of Idaho affirmed the district court's ruling that section 5-234 did not toll the statute of limitations. It also agreed that the claims against Meacham and the Individual Defendants were time-barred under section 1367(d) because the Brays did not file within 30 days after the federal court dismissed those claims. However, the court found that section 1367(d) did toll the time for filing the complaint against IDJC, but IDJC was immune from the claims under Idaho Code section 6-904B(5). The court upheld the district court's award of attorney fees and costs to the defendants and awarded attorney fees and costs on appeal to the respondents. View "Bray v. ID Dept of Juvenile Corrections" on Justia Law

In 2021, Aaron Von Ehlinger, a first-year member of the Idaho State House of Representatives, was accused of rape by J.V., a legislative intern. They had dinner together and later went to Von Ehlinger’s apartment, where J.V. alleged that he sexually assaulted her. Von Ehlinger claimed the encounter was consensual. J.V. reported the incident, and a forensic nurse, Ann Wardle, conducted a sexual assault examination, documenting J.V.'s account and collecting evidence. Von Ehlinger was charged with rape and sexual penetration by use of a foreign object.The case proceeded to trial in April 2022 in the District Court of the Fourth Judicial District of Idaho. During the trial, Wardle testified about J.V.'s statements, which were admitted despite objections from Von Ehlinger’s defense on hearsay grounds. J.V. testified briefly but left the courtroom before cross-examination, leading the court to strike her testimony. The jury found Von Ehlinger guilty of rape but acquitted him of the second charge. The district court denied Von Ehlinger’s motion for acquittal or a new trial and sentenced him to 20 years in prison, with 8 years fixed.The Idaho Supreme Court reviewed the case. Von Ehlinger argued that his Sixth Amendment rights were violated by the admission of Wardle’s testimony and that the district court erred in allowing a leading question. The court found that Von Ehlinger failed to demonstrate that the admission of Wardle’s testimony was fundamental error, as his counsel’s failure to object could have been a tactical decision. The court also determined that any error in allowing the leading question was harmless, as Wardle did not answer the question directly. The court affirmed the judgment of conviction, concluding that there was sufficient evidence to support the jury’s verdict. View "State v. Von Ehlinger" on Justia Law