Justia Criminal Law Opinion Summaries

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

The State of Idaho charged Lea Anne Eaton with felony burglary and petit theft after she used discarded Walmart receipts to return stolen items for a refund. Shortly after her arrest, a new statute creating the misdemeanor offense of commercial burglary became effective. Eaton sought to reduce her felony charge to a misdemeanor under the new statute, but the district court denied her motion. Eaton entered a conditional guilty plea to felony burglary, reserving her right to appeal the denied motion. The district court sentenced her to a unified ten-year sentence with four years fixed. Eaton's subsequent motions to reconsider the denial and to correct an illegal sentence were also denied.The Idaho Court of Appeals upheld Eaton’s conviction and sentence. Eaton then petitioned for review by the Idaho Supreme Court, which granted the petition.The Idaho 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 Court held that the commercial burglary statute was not retroactive and did not apply to Eaton’s conduct, as there was no clear legislative intent for retroactivity. The Court also determined that the commercial burglary statute created a new offense with distinct elements from the general burglary statute, and thus, Eaton was properly charged under the existing felony burglary statute. Consequently, Eaton was not entitled to the lesser penalty of the commercial burglary statute, and her sentence under the felony burglary statute was not illegal.The Idaho Supreme Court affirmed the district court’s judgment of conviction and the denial of Eaton’s Rule 35(a) motion. View "State v. Eaton" on Justia Law

Gerardo Raul Chavez was convicted of second-degree murder for the 2016 killing of Vason Widaman. While in custody for a probation violation, Chavez made incriminating statements to a cellmate, Manuel Acevedo, who was acting as a confidential informant. The State sought to introduce these recordings at trial. Chavez moved to suppress the statements, but the district court only partially granted the motion, suppressing a few statements. The jury acquitted Chavez of first-degree murder but convicted him of second-degree murder with a firearm enhancement. Chavez was sentenced to an indeterminate life sentence with a 42-year fixed term. Post-trial, Chavez's motions for a new trial and permission to contact jurors were denied.Chavez appealed, arguing that the district court erred in denying his motion to suppress, abused its discretion in sentencing, violated his constitutional rights by considering acquitted conduct at sentencing, and erred in denying his motion to contact jurors. The Idaho Supreme Court reviewed the case.The Idaho Supreme Court affirmed the district court's decision. It held that the district court did not err in admitting Chavez's statements, as they were not deliberately elicited by Acevedo. The court also found no abuse of discretion in the 42-year fixed sentence, noting that it fell within statutory limits and was justified by the aggravating factors. The court further held that considering acquitted conduct at sentencing did not violate Chavez's constitutional rights. Finally, the court found no abuse of discretion in denying the motion to contact jurors, as Chavez failed to show good cause for suspecting juror misconduct. View "State v. Chavez" on Justia Law

Michael Anthony Pulizzi was convicted of felony possession of methamphetamine and destruction, alteration, or concealment of evidence. Pulizzi argued that the district court erred in denying his motion to suppress evidence obtained from warrantless searches and seizures of his trash, which he claimed violated his rights under the Idaho Constitution. He contended that the Twin Falls City waste collection ordinances created an objectively reasonable expectation of privacy in his trash.The District Court of the Fifth Judicial District of Idaho denied Pulizzi’s motion to suppress, finding that the waste collection ordinance did not create a reasonable expectation of privacy. The court concluded that the ordinance did not mandate participation in the city’s waste collection program and that the prohibition against collecting garbage for monetary gain did not apply to law enforcement officers. Pulizzi then pled guilty to the charges under a conditional plea agreement, preserving his right to appeal the suppression ruling.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court’s judgment. The court held that the waste collection ordinance did not create an objectively reasonable expectation of privacy in Pulizzi’s trash. The court declined to reconsider its previous holdings in State v. Donato and State v. McCall, which aligned with the U.S. Supreme Court’s decision in California v. Greenwood, stating that there is no reasonable expectation of privacy in garbage left for collection in a public area. The court found that the ordinance’s purpose was to promote public health and safety, not to protect privacy interests in curbside garbage. Consequently, the court affirmed Pulizzi’s conviction. View "State v. Pulizzi" on Justia Law

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt earlier this year due to the inability to establish reliable peripheral intravenous access. The execution team spent nearly an hour attempting to establish venous access in various parts of Creech’s body, but each attempt resulted in vein collapse, leading to the procedure being halted. Following this, Creech sought post-conviction relief, which was denied by the district court and affirmed on appeal.While his post-conviction appeal was pending, Creech applied for a writ of habeas corpus in the district court, arguing that any further attempt to carry out his death sentence would violate his constitutional rights. The district court summarily dismissed Creech’s application with prejudice. Creech appealed, contending that the State’s revised standard operating procedure and execution protocols constitute cruel and unusual punishment.The Supreme Court of the State of Idaho reviewed the case. The court noted that the Idaho Department of Correction had modified its standard operating procedure for executions to allow a qualified physician to establish a central line if peripheral vein access is not attainable. Creech’s application for a writ of habeas corpus included three claims, but only Claim Two, which challenged the use of a central venous line as cruel and unusual punishment, was before the court on appeal.The court held that Creech failed to establish a prima facie challenge to the State’s method of execution. The court found that the use of a central line catheter is a common medical procedure and does not rise to the level of indecency or cruelty prohibited by the United States Constitution. Additionally, Creech failed to propose an alternative method of execution, as required to assert a “method of execution” challenge. The Supreme Court of the State of Idaho affirmed the district court’s order of dismissal. View "Creech v. Randy Valley" on Justia Law

Dustin Mansfield was convicted of introducing contraband into a correctional facility. In January 2021, Mansfield was charged after suboxone strips were found in his mail at the Bannock County jail. The State filed an Information against him, and he was arraigned in March 2021. Mansfield filed a motion to suppress evidence, which delayed the trial initially set for August 2021. The trial was rescheduled multiple times due to Mansfield's motions and the COVID-19 pandemic, which led to emergency orders prohibiting jury trials.The District Court of the Sixth Judicial District of Idaho denied Mansfield's motion to dismiss based on a speedy trial violation, citing the pandemic and emergency orders as good cause for the delay. Mansfield entered a conditional guilty plea, reserving the right to appeal the denial of his motion to dismiss.The Idaho Supreme Court reviewed the case and affirmed the district court's judgment. The court held that the delays caused by the COVID-19 pandemic and the related emergency orders constituted good cause under Idaho Code section 19-3501(2). The court also applied the Barker v. Wingo factors to assess the constitutional speedy trial claim. It found that while the fourteen-month delay was significant, the reasons for the delay, including the pandemic and Mansfield's own motions, were justified. Mansfield's late assertion of his right to a speedy trial and the lack of specific prejudice to his defense further supported the court's decision. Thus, the Idaho Supreme Court concluded that Mansfield's statutory and constitutional rights to a speedy trial were not violated, and his conviction was affirmed. View "State v. Mansfield" on Justia Law

Fernando Rodriguez, an inmate at an Idaho Department of Correction (IDOC) facility, was involved in a disturbance in April 2021. During the incident, inmates threw objects, barricaded doors, and started fires. Rodriguez was identified as one of the inmates who dumped soap on the floor near a door. The State charged Rodriguez with riot and arson, alleging he created a disturbance of the peace and caused property damage.The magistrate court found probable cause for the riot charge but not for the arson charge, binding Rodriguez over to the district court. Rodriguez moved to dismiss the riot charge, arguing that his actions did not meet the statutory requirements for a riot under Idaho Code section 18-6401. The district court agreed, concluding that dumping soap did not cause property damage and that the disturbance of the public peace provision did not apply to a prison setting. The district court dismissed the riot charge.The Supreme Court of the State of Idaho reviewed the case. The court held that the term "public peace" in Idaho Code section 18-6401 unambiguously refers to the exterior or sensory peace of the public writ large, which can be disturbed by conduct occurring inside a prison. The court also found that there was probable cause to believe Rodriguez committed the crime of riot by acting together with other inmates to disturb the public peace and cause property damage. The court reversed the district court's decision and remanded the case with instructions to reinstate the riot charge against Rodriguez. View "State v. Rodriguez" on Justia Law

Robert Kenneth Wilde was charged with two felonies, including trafficking in heroin, and one misdemeanor possession of a controlled substance. One felony charge was dismissed, and Wilde pleaded guilty to trafficking in heroin, with the misdemeanor charge dismissed as part of a plea agreement. The plea agreement included a provision for Wilde to pay drug restitution for investigation costs. Wilde was sentenced to a mandatory minimum of ten years in prison, followed by twenty years indeterminate, and ordered to pay a $15,000 fine and $291 in restitution to the Idaho State Police. The State sought additional restitution for investigative costs, which Wilde contested, citing his lengthy sentence and diminished earning potential.The district court ordered Wilde to pay an additional $2,806.40 in restitution, considering his foreseeable ability to repay. Wilde appealed, and the Court of Appeals held that he waived his right to appeal the restitution order based on his plea agreement. The Court of Appeals also addressed the merits, concluding that Wilde failed to show error in the district court's decision.The Supreme Court of Idaho reviewed the case and disagreed with the Court of Appeals' decision to raise the issue of appellate waiver sua sponte, as the State had not raised it. The Supreme Court found that Wilde's plea agreement did not contain an appellate waiver regarding restitution under Idaho Code section 37-2732(k). On the merits, the Supreme Court held that the district court did not abuse its discretion in awarding additional restitution, as it adequately considered Wilde's foreseeable ability to repay, supported by substantial evidence. The Supreme Court affirmed the district court's restitution order. View "State v. Wilde" on Justia Law

Adrian Renee Soliz was found unconscious behind the wheel of his vehicle, which was impeding traffic. Concerned, a passerby called 9-1-1, and emergency responders arrived at the scene. They discovered drug paraphernalia on Soliz's lap while providing medical assistance for what was later confirmed to be a drug overdose. Soliz was subsequently charged with possession of a controlled substance, possession of drug paraphernalia, and other related offenses.Soliz filed a motion to dismiss the charges, arguing that under Idaho’s overdose immunity statute (Idaho Code section 37-2739C(2)), he should be immune from prosecution because the evidence was obtained as a result of his medical emergency. The State opposed the motion, contending that the evidence was discovered during a traffic investigation, not solely due to the medical emergency. The district court denied Soliz’s motion, concluding that the evidence was not obtained solely as a result of the medical emergency.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The Court held that the phrase “as a result of” in the overdose immunity statute means that the drug-related medical emergency must be the sole cause of the discovery of evidence. Since the evidence was discovered during both a traffic investigation and a medical emergency response, the statute did not apply. Therefore, Soliz was not entitled to immunity, and the district court’s denial of his motion to dismiss was upheld. View "State v. Soliz" on Justia Law