Justia Criminal Law Opinion Summaries

In 2016, John Doe was cited for petit theft. Doe’s disposition hearing was held, and the magistrate court committed Doe to the custody of Idaho Department of Juvenile Corrections (“IDJC”). the magistrate court ordered Doe’s father, Dennis Dudley, to reimburse IDJC for expenses incurred in caring for and treating Doe pursuant to Idaho Code section 20-524(1). Doe and Dudley appealed the reimbursement order to the district court. The district court, acting in its intermediate appellate capacity, affirmed. Doe and Dudley timely appealed the district court’s decision. The Idaho Supreme Court dismissed the appeal, finding the reimbursement order against Dudley was not a final appealable order. View "IDJC v. Dudley" on Justia Law

Glen Ward appealed an order and final judgment of the district court granting the State’s motion for summary dismissal and dismissing his petition for post-conviction relief. In 2014, Ward was convicted of sexual abuse of a minor under 16 years of age after he pleaded guilty to all elements of the crime except for the sexual intent element, to which he entered an Alford plea. He was sentenced to 18 years imprisonment with a 7-year fixed term. Ward asked for, and was granted, appointment of counsel to represent him in the post-conviction relief proceedings. After granting the motion, the district court appointed a conflict public defender to represent Ward in the action. Although he had secured new counsel, Ward subsequently filed numerous pro se documents. Ward argued the district court abused its discretion by denying his motion to proceed pro se as moot. Ward also argued the district court erred in denying his motion to proceed pro se because a post-conviction petitioner has a right to proceed pro se. After review, the Idaho Supreme Court vacated in part and affirmed. The Court held that the district court should have refused to entertain Ward’s independent filings in the first place; to the extent that the district court entertained the filings made by Ward as opposed to by his attorney, it was error to do so. However, having come to the conclusion that the district court erred, not by ruling incorrectly on Ward’s purported motion, but by ruling on it at all, the Supreme Court did not need to reverse the district court’s separate order and final judgment granting summary dismissal. "Because we hold that there was no motion properly before the district court to be ruled upon in the first place, the district court’s denial of the purported motion has no impact on the propriety of its final decision and judgment dismissing Ward’s post-conviction petition on the merits." View "Ward v. Idaho" on Justia Law

On the evening of June 17, 2018, Appellants Shane Dodge and his wife Christine (“the Dodges”) were returning home with their son after having dinner together, when they turned onto District Two Road and saw a police car partially blocking their lane of travel. At that time, two Bonners Ferry police officers, Sergeant William Cowell and Officer Brandon Blackmore, were conducting a traffic stop of another vehicle. To avoid hitting them, Shane drove slowly by the two cars, and then pulled over about four car-lengths away. He exited his car and approached the police officers. He informed them that the location “was a pretty stupid place to pull people over.” Sergeant Cowell instructed Shane that he could be arrested for obstruction or interfering with the traffic stop, whereupon Shane said, “go to hell.” Shane was then arrested and placed in the back of the patrol car. When she saw her husband being arrested, Christine exited her car and attempted to approach and question the officers. When she asked the officers why they were arresting her husband, Sergeant Cowell told Officer Blackmore to arrest her too, but Officer Blackmore ordered her to leave the scene. Shane was taken to the county jail and booked. Thereafter, he posted bond and was released. The Dodges appealed after a district court dismissed their tort claim against the Bonners Ferry Police Department, Sergeant Cowell and Officer Blackmore. The grounds for dismissal was failing to file a notice of tort claim pursuant to Idaho Code sections 6-610 et seq., and for failing to post a bond prior to commencing their cause of action. Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Dodge v. Bonners Ferry Police Department" on Justia Law

This appeal came from a district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” Picatti contended Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers (I.C. § 18-705), and aggravated battery on law enforcement. Ultimately, Picatti was convicted, accepting a plea agreement to disturbing the peace and failure to obey a traffic sign. Two years later, Picatti brought his 42 U.S.C. 1983 suit, claiming he was deprived of his rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the deputies, holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. The Idaho Supreme Court affirmed summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

Due to a failed breath alcohol test and multiple convictions for driving under the influence, the Idaho Transportation Department permanently suspended Bruce Edwards’ driving privileges to operate a commercial motor vehicle. The district court affirmed the Department’s order and Edwards appealed. After review of the Department’s order and the circumstances leading to the suspension, the Idaho Supreme Court affirm the district court’s judgment and the Department’s lifetime disqualification of Edwards’ commercial motor vehicle driving privileges. View "Edwards v. Transportation Dept" on Justia Law

This appeal arose from the district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In July 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” The factual background from that point was heavily disputed. Picatti alleged Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers and aggravated battery on law enforcement. At the end of his preliminary hearing, Picatti was bound over. Prior to trial, Picatti accepted a plea agreement in which he pleaded guilty to disturbing the peace for “failing to obey a traffic sign and driving into a restricted pedestrian area.” The court entered a judgment of conviction, which was not appealed, overturned, or expunged. Two years later, Picatti brought a 42 U.S.C. section 1983 suit against his arresting deputies, claiming deprivations of his protected rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the defending deputies holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. Picatti timely appealed. The Idaho Supreme Court affirmed the order granting summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated the summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

Mother Jane Doe appealed a magistrate court’s termination of her parental rights to her child T.G.E. At the time she gave birth, Mother had pending felony drug charges and an active warrant for her arrest; the child’s umbilical cord tested positive for methamphetamine at birth. Following a termination hearing, the magistrate court found termination proper based on neglect and entered an order to that effect on December 8, 2017 (the Order). However, in a subsequent decree (the Decree) issued on December 15, 2017, the magistrate court stated Mother’s parental rights were being terminated based on abandonment. The court also terminated Father’s parental rights however, Father had voluntarily relinquished his parental rights and was not a party to this appeal. On appeal, both Mother and the Department raised procedural issues relating to the conflicting Order and Decree. Subsequently, the Idaho Supreme Court remanded the case for entry of a new judgment terminating Mother and Father’s rights to Child, and stated the Order would constitute the findings of fact and conclusions of law. Mother appealed, contenting the magistrate court erred when it terminated Mother’s parental rights. Finding no reversible error, the Supreme Court affirmed the ultimate termination. View "DHW v. Jane Doe" on Justia Law

Saint Alphonsus Regional Medical Center, Inc. (“Saint Alphonsus”) appealed the grant of summary judgment in favor of Ada County Sheriff, Gary Raney, in his official capacity; Ada County; and the Board of Ada County Commissioners, (collectively, “Ada County”). The district court ruled as a matter of law that Ada County was not obligated to pay for an inmate’s (“Patient”) entire hospitalization where the State sought a release from custody during the hospitalization so the inmate could receive medical treatment. The district court ruled that Ada County’s obligation to pay for the hospitalization stopped once a release order was entered. The Idaho Supreme Court held the district court erred in its interpretation of Idaho Code sections 20-605 and 20-612 and vacated the judgment entered in favor of Ada County. View "St. Al's RMC v. Ada Co Sheriff" on Justia Law

This was an appeal of a judgment against a bail bondsman who revoked a bail bond for an illegal alien at the request of an agent of United States Immigration and Customs Enforcement. The district court awarded damages in the amount of the bail bond premiums, and the appellants contended on appeal that they were entitled to additional damages. The Supreme Court found no reversible error in the district court's judgment and affirmed. View "Garcia v. Absolute Bail Bonds" on Justia Law

In 2006, John Doe (“Father”) and Mother were the parents of three minor daughters who were approximately 5, 6, and 7 years of age. A federal grand jury in Idaho issued an indictment charging Father with hiring someone from out of state to kill Mother. The indictment alleged that Father had agreed to pay that person $10,000. A jury found Father guilty, and the federal court sentenced him to 120 months in the custody of the United States Bureau of Prisons and three years of supervision following his release from prison. The federal court also sentenced him to a fine of $17,500. Following Father’s arrest and incarceration, Mother had sole custody of their three minor daughters. By 2013, the girls were 12, 13 and 14. Mother was having psychological issues and tried to take her own life; the eldest daughter also had attempted suicide. The State intervened and filed for protection under the Child Protective Act. The Department of Health and Welfare recommended the girls remain in shelter care due to an unstable home environment; Father wanted the girls placed with his adult son in Arizona. Ultimately, termination of Father's parental rights was recommended and granted. Father appealed, arguing the evidence of abandonment and neglect was insufficient to support termination of parental rights. Finding no reversible error in this respect, the Supreme Court affirmed the termination of Father's parental rights. View "Idaho Dept. of Health & Welfare v. John Doe (2016-09)" on Justia Law