Justia Criminal Law Opinion Summaries

Plaintiff-appellant Barry Searcy was an inmate in the custody of the Idaho Department of Correction (IDOC). In 2011, he filed a civil complaint naming as defendants the Idaho State Board of Correction, IDOC, and various individual defendants in their official capacities (collectively “the Board”). Searcy’s complaint alleged that the Board illegally charged inmates fees for: (1) commissary goods; (2) telephone calls; (3) photocopying; (4) medical service co-pays; and (5) hobby supplies. The Legislature had not provided express statutory authorization for any of these fees at the time that Searcy brought this action. Instead, the fees were imposed based upon IDOC policy or Standard Operating Procedures (SOPs). The Board moved for summary judgment in all claims, and the district court ultimately granted the Board's motion. Searcy appealed, and his claims “solely challenging the district court’s grant of summary judgment as to Count I” (alleging that raising revenue through the disputed fees exceeded the Board’s rulemaking authority under Idaho Code section 20-212 and caused a wrongful forfeiture of property in violation of Idaho Code section 18-314) were heard by the Court of Appeals. In a split decision, the Court of Appeals affirmed. Searcy petitioned for review, which the Supreme Court granted. After review, the Court determined that the fees at issue here were not unconstitutional fees. As such, it affirmed the Court of Appeals' judgment. View "Searcy v. Idaho Bd of Correction" on Justia Law

At the heart of this appeal was a dispute about the duration of an administrative suspension of an Idaho driver’s license. Respondent Susan Warner was convicted in Idaho of driving under the influence of alcohol (DUI). Two years later, she was convicted in Montana on another DUI charge. Upon receiving notice of the Montana conviction, the Idaho Department of Transportation administratively suspended Warner’s driver’s license for a period of one year. Warner challenged the duration of the suspension, arguing that because the Montana conviction was not for a “second DUI” the maximum allowed suspension was thirty days. The Department rejected Warner’s challenge, but on judicial review, the district court reduced the suspension from one year to thirty days. The Department appealed. Finding that the district court erred in reducing the suspension; "it was not error for the Department to apply Idaho Code section 18-8005(4)(e) to impose an administrative suspension for one year based on the Montana DUI being a second rather than a first DUI conviction." The Court vacated the district court's decision and remanded for further proceedings. View "Warner v. Idaho Transportation Dept" on Justia Law

In 2012, Rayland Brown was charged by indictment with the felony crime of forcible sexual penetration by use of a foreign object. On the second day of Brown’s jury trial, he and the State agreed to a written plea agreement. One of the provisions of the plea agreement was that the charge would be amended to felony domestic battery. On the same date, the State filed an information charging the crime of felony domestic battery, and Brown pled guilty to that charge. The district court sentenced Brown, and in accordance with the plea agreement the court retained jurisdiction for 365 days. A year later, the court entered an order relinquishing jurisdiction, which resulted in Brown being required to serve a prison sentence of at least fifteen years and up to twenty years, with credit for 483 days already served. Brown filed a motion for reconsideration, and the court reduced the mandatory portion of the prison sentence from fifteen years to eleven years. Brown then filed this civil action seeking post-conviction relief on the ground that he received ineffective assistance of counsel in his criminal case. The district court interpreted the alleged ineffective assistance as being that his counsel advised him that he would receive probation after the period of retained jurisdiction and failed to object to the court’s alleged deviation from the plea agreement. The district court dismissed the petition for post-conviction relief because the court in the underlying case did not deviate from the plea agreement and the plea agreement, which Brown signed, notified him that he may not receive probation because it expressly provided that “[a]t the end of the period of retained jurisdiction, the court would be free to exercise or relinquish jurisdiction in its discretion.” Brown then appealed, challenging whether the court in his criminal case had subject-matter jurisdiction. The Supreme Court concluded Brown could not raise that issue for the first time on appeal in this civil action, and affirmed the judgment in this case. View "Brown v. Idaho" on Justia Law

In 1992, Todd Rich was indicted for felony rape, allegedly committed between November 1991 and January 1992; he pled guilty on August 19, 1992; and on October 23, 1992, the district court sentenced him to six years in the custody of the Idaho Board of Correction. The district court retained jurisdiction for 120 days, and ultimately suspended the remainder of Rich’s sentence and placed him on probation. Rich successfully completed his probation on or about March 2, 2004. The following day, Rich filed a motion asking the district court in his criminal case for relief pursuant to Idaho Code section 19-2604(2), which was granted. The district court reduced Rich’s charge to a misdemeanor. The order reducing the charge stated that “the Judgment is hereby deemed a misdemeanor conviction, thereby restoring [Rich] to his civil rights.” At some point, Rich moved to Pennsylvania. He apparently applied for permission to possess a firearm in Pennsylvania. His request was denied by an administrative law judge who ordered: “It appearing that under Idaho law, I.C. 18-310(2), final discharge for a conviction of rape does not restore the right to ship, transport, possess or receive a firearm, the determination of the Pennsylvania State Police that Todd Rich is prohibited under the Uniform Firearms Act, 18 Pa. C.S. 6101 et seq., is upheld.” Rich filed this action seeking a declaratory judgment that he “may lawfully purchase, own, possess or have under his custody or control a firearm under the laws of the State of Idaho.” The State responded by contending that Rich had no standing to seek such relief. The district court dismissed the case on two alternative grounds: (1) Rich did not have standing because no real, substantial, and concrete controversy then existed; and (2) “Idaho Code 18-310(3) provides the mechanism for the restoration of civil rights is through application to the commission of pardons and parole, not through the District Court.” The district court entered a judgment dismissing this action with prejudice. Finding no reversible error, the Idaho Supreme Court affirmed. View "Rich v. Idaho" on Justia Law

The State appealed the district court’s decision to affirm the magistrate court’s holding that it did not have jurisdiction over John (2012-10) Doe because he was twenty-one years of age when the State filed its petition in juvenile court. Upon review, the Supreme Court reversed the decision of the district court. View "Idaho v. John Doe (2012-10)" on Justia Law

At issue before the Supreme Court in this case was appeal and cross-appeal of summary judgments dismissing claims against Defendants Ada County, Deputy Jeremy Wroblewski, Kate Pape, and James Johnson in a 42 U.S.C. 1983 civil rights action brought by Rita Hoagland on behalf of herself and the estate of her deceased son, Bradley Munroe ("Munroe"), claiming a violation of a Fourteenth Amendment right to medical care and safety while Munroe was detained at Ada County Jail where he committed suicide. Munroe had a history of incarceration at Ada County Jail ("ACJ"). During the evening of September 28, 2008, Munroe was arrested and charged with the armed robbery of a convenience store. Munroe was intoxicated and uncooperative. During booking, Munroe was screaming and being rowdy. Munroe took a string and wrapped it around his neck. Because of his bizarre behavior throughout the night, Munroe was placed in a holding cell for observation until he was sober. The next morning booking continued. At that time, Munroe requested protective custody. Munroe was placed in a cell by himself and a well-being check was scheduled to occur every thirty minutes. Later that evening during a well-being check, the performing deputy found Munroe hanging from his top bunk by a bed sheet. Munroe was pronounced dead later that evening. Among the issues on appeal were: whether the decedent's estate could assert a 42 U.S.C 1983 action for alleged violations of the decedent's constitutional rights; whether the parent had standing to assert a 42 U.S.C. 1983 action for the death of her adult child while incarcerated; and whether the district court erred in awarding costs to Defendants. Upon review, the Supreme Court concluded that the district court: (1) was affirmed in dismissing Hoagland's 1983 claim on behalf of Munroe's estate; (2) was reversed in finding that Hoagland had a 1983 cause of action for violations of her own constitutional rights; (3) was partially affirmed in its award of costs as a matter of right; (4) was reversed in its award of discretionary costs; and (5) was affirmed in denying attorney fees. The case was remanded for the reconsideration and entry of express findings regarding the district court's award of discretionary costs. View "Hoagland v. Ada County" on Justia Law

Petitioner-Appellant Zane Jack Fields was incarcerated for the 1988 first degree murder of Mary Katherine Vanderford. The district court dismissed his petition for post-conviction relief in 2010, the fifth successive petition for post-conviction relief he filed. In the latest petition, Petitioner argued that the act of destroying an orange camouflage coat (introduced into evidence as a defense exhibit and used by eyewitnesses to identify him) was new evidence that established his innocence. The State moved to dismiss on grounds that Petitioner's newly discovered evidence claims were time-barred by statute, and the district court granted the motion. Upon review, the Supreme Court concluded that the district court was correct in finding Petitioner's petition was untimely filed, and affirmed. View "Fields v. Idaho" on Justia Law

This case arose from a district court's review on appeal of a magistrate court's decision regarding the civil forfeiture of a motorcycle and other items that belong to Christopher Rubey. In 2009, Rubey was arrested and charged with possession of methamphetamine with intent to deliver. Subsequently, the Ada County Prosecutor's Office (State) brought an action under I.C. 37-2744 for civil forfeiture of the motorcycle and related items used in the alleged crime. The magistrate court granted summary judgment to the State, and the district court reversed and remanded that decision. The State appealed to the Supreme Court, arguing that the district court erred in its decision and that the legislative intent behind I.C. 37-2744(a)(4) supports civil forfeiture for either the transportation or trafficking of drugs. Upon review, the Supreme Court agreed and affirmed the district court's decision. View "Ada Co Prosecuting Atty v. 2007 Legendary Motorcycle" on Justia Law

Petitioner-Appellant Randall Bottum appealed a district court order which held that a 2009 amendment to the sex offender registration law applied to him. Prior to the amendment, Petitioner could have petitioned the court to be exempted, but the amendment foreclosed that opportunity. Upon review of the district court order, the Supreme Court found that the 2009 amendment applied to Petitioner and affirmed the district court order. View "Bottum v. Idaho State Police" on Justia Law

Michelle Anderson appealed the district court's denial of her motion to dismiss kidnapping charges brought against her for keeping the child she had with Ricky Anderson away. Michelle was obligated to deliver the child to Ricky under a parenting plan issued by a Montana court, but never completed the exchange. In her motion to dismiss, Michelle argued that Ricky is not a custodial parent under I.C. 18-4501 and therefore Michelle could not have committed kidnapping. The district court denied the motion, and the Supreme Court granted permission to appeal that decision. Upon review, the Supreme Court concluded that Ricky was a custodial parent for the purposes of IC 18-4501(2), and that Michelle could be charged with kidnapping based on Ricky's visitation rights that granted him lawful care and control of the child. Accordingly, the Court affirmed the district court's decision. View "Idaho v. Anderson" on Justia Law