Justia Criminal Law Opinion Summaries

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

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

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 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

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court's denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith's motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and inventory search of his vehicle were reasonable and conducted according to police procedures. Smith was subsequently convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the State did not meet its burden to show that the police officer's decision to impound Smith's vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. As a result, the evidence obtained from the search was inadmissible, leading to the vacating of Smith's conviction. View "State v. Smith" on Justia Law

Daniel Ruiz Ortiz was convicted of second-degree murder and violating a no contact order (NCO). Ortiz appealed, arguing that the district court erred in denying his motion to suppress evidence obtained during a warrantless search of his home and a subsequent search conducted with a warrant. The district court relied on the Idaho Supreme Court's decision in State v. Rebo, which held that Ortiz lacked Fourth Amendment standing to challenge the warrantless search because the NCO prohibited him from being within 300 feet of the residence.The district court found that Ortiz did not have standing to challenge the search, as he was prohibited by the NCO from being near the home. Ortiz's case proceeded to a jury trial, where he was found guilty of second-degree murder and violating the NCO. He was sentenced to life in prison, with the first thirty years fixed. Ortiz appealed the denial of his motion to suppress, arguing that the Rebo decision should be overruled or that his case was distinguishable from Rebo.The Idaho Supreme Court reviewed the case and declined to overrule Rebo, finding that Ortiz failed to demonstrate that the decision was manifestly wrong. The court also found that while Ortiz's case was factually distinguishable from Rebo, he still lacked Fourth Amendment standing to challenge the warrantless search. The court held that Ortiz did not have a reasonable expectation of privacy in the home due to the NCO and that law enforcement's entry into the home was justified by exigent circumstances, as they were concerned for Ruiz's safety.The Idaho Supreme Court affirmed the district court's decision, concluding that Ortiz did not have standing to challenge the warrantless search of his home. View "State v. Ortiz" on Justia Law

Lance A. Roberts appealed the district court's decision affirming the magistrate court's denial of his Idaho Criminal Rule 35 motion in a misdemeanor DUI case, his Rule 35 motions in felony DUI cases, and the dismissal of his petitions for post-conviction relief in those felony DUI cases. Roberts sought to amend his multiple DUI convictions over the past two decades, arguing that his April 1998 conviction for a second "adult" misdemeanor DUI should have been charged as a second "juvenile" misdemeanor DUI. He claimed this error had a domino effect, leading to subsequent DUIs being charged as felonies and resulting in a persistent violator sentencing enhancement in his most recent felony DUI case.The magistrate court initially granted Roberts' Rule 35 motion to amend his April 1998 conviction, but the State's motion to reconsider was denied. Roberts then filed multiple motions and petitions to amend his subsequent DUI convictions and eliminate the persistent violator enhancement. The magistrate court denied these motions, and the district court affirmed, concluding that neither Rule 35(a) nor post-conviction relief statutes authorized the requested relief. The district court also reversed the magistrate court's amendment of the April 1998 conviction and dismissed Roberts' petitions for post-conviction relief.The Idaho Supreme Court reviewed the case and upheld the district court's decisions. The Court held that Idaho Criminal Rule 35(a) does not allow for the amendment of a criminal conviction and is limited to correcting illegal sentences apparent from the face of the record. The Court also affirmed that Idaho Code section 19-4901(a) does not permit the relief Roberts sought, as his claims were time-barred and could have been raised on direct appeal. Consequently, the Court affirmed the district court's denial of Roberts' motions and petitions for post-conviction relief. View "State v. Roberts" on Justia Law

The defendant, Jameel Fakhri Al Muthafar, was convicted of aggravated assault and attempted strangulation. The case arose when K.S., the victim, called the police from a Rite Aid store in Boise, Idaho, expressing suicidal thoughts and claiming she had been attacked by her romantic partner, Al Muthafar. K.S. was taken to St. Alphonsus Hospital, where she was diagnosed with injuries from an alleged assault. She was then referred to FACES for a forensic examination, during which she described the assault and identified Al Muthafar as the perpetrator.At the preliminary hearing, the magistrate court admitted hearsay statements made by K.S. to a nurse during the FACES examination, over Al Muthafar’s objection. The magistrate court found probable cause to bind the case over to the district court. Al Muthafar filed a motion to dismiss the Information, arguing that the hearsay statements were inadmissible and that without them, there was insufficient probable cause. The district court denied the motion, and the case proceeded to trial, where Al Muthafar was found guilty by a jury.The Supreme Court of Idaho reviewed the case and determined that the magistrate court erred in admitting the hearsay statements at the preliminary hearing, as the State failed to establish that the statements were made for the purpose of medical diagnosis or treatment. However, the court held that this error was harmless because Al Muthafar received a fair trial, where the jury found him guilty beyond a reasonable doubt based on properly admitted evidence.Additionally, the court reviewed Al Muthafar’s sentence of fifteen years with five years fixed and found no abuse of discretion by the district court. The sentence was deemed reasonable given the severity of the charges, the defendant’s risk of future violence, and his lack of remorse. The Supreme Court of Idaho affirmed both the conviction and the sentence. View "State v. Al Muthafar" on Justia Law