Justia Criminal Law Opinion Summaries

The issue in this case came from an appeal of a decision of the Industrial Commission which found that claimant Joseph Henry failed to prove that the heart attack he suffered while at work was an industrial accident because his cardiologist could not determine whether the plaque rupture that caused the heart attack was triggered by events occurring before or after the claimant arrived at work. Upon review, the Supreme Court held that the Commission’s findings of fact were not clearly erroneous and affirmed its order denying compensation. View "Henry v. Dept of Corrections" 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

This appeal arose from the district court's reversal of the Idaho Transportation Department's (Department) suspension of Johnathan Paul Van Camp's driver's license subsequent to a urine analysis that revealed the presence of cyclobenzaprine in his system. The district court held that the Department had not properly shown that cyclobenzaprine was intoxicating. The Department timely appealed, arguing that the arresting officer's observations of impairment, in combination with an evidentiary test revealing a drug in Van Camp's system, were sufficient to permit an administrative license suspension. The Department asked the Supreme Court to reverse the district court's decision vacating the suspension. Finding that Van Camp failed to establish a proper ground to support an order vacating the suspension, the Supreme Court reversed the district court and remanded the case for further proceedings. View "Idaho Dept. of Trans. v. Van Camp" on Justia Law

The issue on appeal in this case came from a decision of a district court which held that in a hearing regarding an administrative license suspension pursuant to Idaho Code section 18-8002A, the hearing officer must consider the margin of error of the breath testing machine when determining whether the test results support suspension. Facing a license suspension, Defendant Alma Elias-Cruz argued at trial that any suspension must be based upon her actual blood alcohol concentration rather than the alcohol concentration as shown by the test because, due to the test's margin of error, her actual blood alcohol content could have been below the statutory limit, and that the testing equipment had not been calibrated once a year as recommended by its manufacturer. The district court ruled sua sponte that her due process rights were violated by the hearing officer's rejection of the equipment's margin of error and that she had a statutory right to present such evidence. The court vacated the hearing officer's decision and ordered the matter remanded. The State then timely appealed. The Supreme Court reversed: "[u]nder Idaho Code section 18-8002A(1)(e), by definition the test results show the alcohol concentration. The issue is not the alcohol concentration in the blood. It is the alcohol concentration as shown by the test results. There is nothing to which to compare the test results. All that is required is that the test results show that the alcohol concentration was above the legal limit." The Supreme Court concluded the district court erred in its interpretation of that statute.

A State trooper arrested Respondent Jason Miller for DUI. The trooper observed that Respondentâs pupils were dilated and asked that Respondent perform some field sobriety tests, which Respondent ultimately failed. The trooper discovered scissors in Respondentâs pocket that were used for cleaning a marijuana pipe. Respondent admitted to smoking marijuana âevery day.â The trooper took respondent to a hospital for a urine test, but at the hospital, Respondent refused to willingly provide a sample. A registered nurse at the hospital then catheterized Respondent at the trooperâs request, and extracted the sample. Respondent later pled guilty to possession of drugs, drug paraphernalia and to DUI. Respondent appealed the trial courtâs grant of summary judgment to the State. He argued that his civil rights under 42 U.S.C 1983 and state tort laws were violated when he was âunreasonablyâ catheterized. The Supreme Court found that because âAmerican search-and-seizure law is undeveloped as to when an officer may administer an involuntary warrantless catheterization on a suspect,â the state trooper was entitled to qualified immunity for both of Respondentâs the federal and state law claims.