Justia Criminal Law Opinion Summaries

The case involves Todd Marshall Frandsen, who was charged with three counts of lewd conduct with minors under sixteen, based on allegations from his three sons. The boys reported that Frandsen engaged in lewd and abusive conduct, including fondling and other forms of mistreatment, over many years. Each son described similar patterns of abuse, which included threats and psychological intimidation. Frandsen was tried before a jury in Bannock County, Idaho, in March 2023.After a four-day trial, the jury convicted Frandsen of two counts related to the older boys and acquitted him of the charge involving the youngest. Frandsen was sentenced to two concurrent life sentences with 25-year fixed terms, later reduced to 20 years fixed upon his motion for reconsideration. He filed timely appeals, arguing that the district court erred by not removing a juror who recalled knowing one of the victims, admitting certain text messages between a victim and their mother, permitting a forensic interviewer to offer expert-like testimony without proper disclosure, and imposing an excessive sentence.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in retaining the juror, as she provided unequivocal assurances of impartiality and her past acquaintance with a victim did not establish actual or implied bias. The Court found the text messages were relevant and non-hearsay, though it did identify harmless error in admitting references to uncharged physical abuse without required Rule 404(b) notice. Similarly, it determined that the forensic interviewer’s limited expert testimony, though improper due to non-disclosure, was harmless given the acquittal on the related charge. The Court also found that the sentence imposed was not excessive. Accordingly, the Idaho Supreme Court affirmed the convictions and sentences. View "State v. Frandsen" on Justia Law

A woman was convicted of possessing methamphetamine and drug paraphernalia after police discovered these items during a search of a residence she shared with another individual who was on probation. The search was initiated when a probation officer visited to verify the housemate's residence. The woman answered the door, attempted to refuse entry by shutting the door, but the officer entered regardless and proceeded to search the shared bedroom after both occupants indicated there might be contraband present. The officer found drugs and paraphernalia in the room, and both individuals were charged.Previously, the District Court of the Fourth Judicial District, Ada County, denied the woman's motion to suppress the evidence, rejecting her argument that the search was unlawful under Georgia v. Randolph because she had expressly objected to the entry. The district court also admitted a police body camera video at trial, which included statements from her housemate that allegedly violated her Sixth Amendment confrontation rights under Bruton v. United States. The case proceeded to a joint jury trial, resulting in guilty verdicts for both defendants.The Supreme Court of the State of Idaho reviewed the case. It held that the search was lawful because the probationer's waiver of Fourth Amendment rights as a condition of probation allowed officers to enter and search shared areas, even over the objection of a co-occupant. The Court declined to extend the Randolph rule to probation searches, reasoning that co-tenants of probationers have a reduced expectation of privacy. Regarding the confrontation issue, the Court found that admitting the body camera footage was error under Bruton, but determined the error was harmless due to overwhelming independent evidence of guilt. The Court affirmed the district court’s judgment of conviction. View "State v. Horn" on Justia Law

Police responded to a report of a disturbance at a man’s home, where they learned from his girlfriend that he was a convicted felon in possession of firearms. The man admitted that he knew about the firearms and had purchased two for his children. He led officers through his home, where they recovered three firearms and ammunition. The State charged him with three counts of unlawful possession of a firearm by a convicted felon.The case progressed through the Idaho courts, beginning with the magistrate court, where the man repeatedly stated he could not afford an attorney and wanted “effective assistance of counsel,” rather than representation. The magistrate court suggested he did not qualify for a public defender due to his employment, and the preliminary hearing proceeded with the defendant unrepresented, after which he was bound over to the district court. Throughout proceedings before the district court, the man continued to appear without counsel, filing many pro se motions. Eventually, after much confusion about his wishes, the district court appointed “shadow counsel” to assist him at trial, but continued to treat him as self-represented. The jury convicted him on all counts, and the district court denied his post-trial motions.The Supreme Court of the State of Idaho reviewed the case after the Idaho Court of Appeals affirmed the convictions. The Supreme Court held that the appointment of “shadow counsel” did not satisfy the Sixth Amendment right to counsel because the defendant, not an attorney, controlled and managed his defense. The Court further held that the record did not show the defendant knowingly, intelligently, and voluntarily waived his right to counsel, as required by law. As a result, the Supreme Court vacated the judgment of conviction and remanded the case for further proceedings. View "State v. Knight" on Justia Law

Sheryl Robertson was arrested in Custer County, Idaho, for felony possession of methamphetamine and ultimately pleaded guilty pursuant to a plea agreement. The district court sentenced her to a ten-year term, retained jurisdiction for one year, and later placed her on probation with additional requirements after she admitted to multiple probation violations. These requirements included completing 100 hours of community service and successfully participating in a treatment court program. Robertson entered the Bonneville County Wood Court but encountered issues with the program and requested transfer to a different treatment court. The State subsequently moved to terminate her participation in Wood Court and revoke her probation, alleging further rule violations.Robertson waived her right to a termination hearing in Wood Court using forms that referenced only the treatment court termination, not probation revocation. The district court proceeded directly to disposition on the alleged probation violation, reasoning that Robertson’s waiver in Wood Court extended to her right to a probation-revocation hearing. Robertson was sentenced to a modified term of incarceration, and she appealed. The Idaho Court of Appeals affirmed the district court, finding that the procedures under the Idaho Rules for Treatment Courts (I.R.T.C.) were followed and provided the required due process, but declined to address whether Robertson had received the process required by the Fourteenth Amendment as articulated in Morrissey v. Brewer.The Supreme Court of the State of Idaho reviewed the case and held that Robertson’s waiver of her right to a probation-revocation hearing was not knowing and intelligent, as required by the Due Process Clause of the Fourteenth Amendment. The forms she signed did not clearly communicate that waiving the Wood Court termination hearing also constituted a waiver of the right to a probation-revocation hearing. The Supreme Court vacated the district court’s order revoking probation and imposing a modified sentence, and remanded the case for a probation-revocation hearing. View "State v. Robertson" on Justia Law

The defendant was charged with felony possession of a controlled substance and two related misdemeanors. He and the prosecution entered into a plea agreement under which he would plead guilty to the felony, the misdemeanors would be dismissed, and he would receive a suspended sentence with probation, provided he complied with certain conditions. The agreement included a clause stating it would be “null and void” if the defendant failed to appear for his presentence appointment or sentencing without good cause. After entering his guilty plea, the defendant failed to appear for both the presentence appointment and sentencing, leading to his arrest on a bench warrant.Following these events, the District Court of the Second Judicial District, Nez Perce County, determined that the “null and void” clause released the State and the court from their obligations under the plea agreement, but held that the defendant remained bound by his guilty plea. The court imposed a sentence inconsistent with the plea agreement and did not allow the defendant to withdraw his plea. The Idaho Court of Appeals affirmed the district court’s judgment.On review, the Supreme Court of the State of Idaho held that the district court erred in its interpretation of the “null and void” clause. The Supreme Court concluded that, under general contract principles, the clause rendered the entire plea agreement unenforceable by either party upon breach, not just by the State. The court further held that, under Idaho Criminal Rule 11(f)(4), once the plea agreement was rendered unenforceable and the court declined to be bound by its terms, the defendant was entitled to an opportunity to withdraw his guilty plea. Because the district court failed to provide this opportunity, the Supreme Court vacated the judgment of conviction and remanded the case for further proceedings. View "State v. McGarvey" on Justia Law

The defendant was arrested for possession of controlled substances in late December 2021 and released on his own recognizance. The State filed an Information in January 2022, charging him with possession of heroin, methamphetamine, and drug paraphernalia. Due to the COVID-19 pandemic, jury trials in Bingham County were suspended until late February 2022, creating a backlog of cases. The defendant’s trial was rescheduled multiple times, primarily because of delays in forensic testing and the unavailability of a forensic analyst. The district court repeatedly warned that older cases and limited judicial resources might further delay the trial. Ultimately, the defendant’s trial did not occur within the six-month statutory period, and he moved to dismiss the case, arguing violations of his statutory and constitutional speedy trial rights.The District Court of the Seventh Judicial District denied the motion to dismiss, finding good cause for the delay due to the backlog of cases resulting from the pandemic and the need to prioritize older cases. The court also noted that the defendant was not in custody, which lessened the prejudice from the delay. The defendant entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the denial of his motion to dismiss.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court erred in denying the motion to dismiss under Idaho Code section 19-3501 and Article I, section 13 of the Idaho Constitution. The Supreme Court held that court congestion resulting from the COVID-19 pandemic constituted good cause for the trial delay under the statute. The Court also rejected the argument that the Idaho Constitution provides greater protection than the federal constitution regarding speedy trial rights, reaffirming the use of the Barker v. Wingo factors. The judgment of conviction was affirmed. View "State v. Fierro-Garcia" on Justia Law

The case concerns a man who was convicted of first degree murder with a deadly weapon enhancement and resisting and obstructing an officer after his uncle was found fatally stabbed in the home they shared. The defendant was located by police shortly after the incident, with injuries and physical evidence linking him to the crime. During jury selection, the only Black juror in the venire was removed by the prosecution using a peremptory strike, prompting the defendant, who is also Black, to raise a Batson challenge alleging racial discrimination. The trial court denied the challenge, finding the State’s reasons for the strike—juror distraction due to personal circumstances and apparent disengagement—were race-neutral and not pretextual. The jury ultimately found the defendant guilty, and he was sentenced to 40 years to life.The Idaho Court of Appeals affirmed the conviction, holding that the defendant had not established a prima facie case of discriminatory intent under Batson v. Kentucky. The defendant then sought review by the Supreme Court of the State of Idaho, arguing that the trial court erred in denying his Batson challenge, limiting cross-examination about alternate perpetrators, and restricting his closing argument. He also invoked the doctrine of cumulative error.The Supreme Court of the State of Idaho clarified that, under Hernandez v. New York, once the prosecution offers a race-neutral explanation and the trial court rules on discriminatory intent, the initial prima facie showing under Batson is moot. The court found no clear error in the trial court’s acceptance of the State’s race-neutral reasons for the peremptory strike. The court also held that the trial court did not abuse its discretion in limiting cross-examination or closing argument, and found no cumulative error. The judgment of conviction was affirmed. View "State v. Buck" on Justia Law

The case concerns a woman who was convicted and sentenced to death in 1993 for the murders of her husband and two children, whom she killed by setting their apartment on fire while they slept. Investigators found evidence of premeditation, including the use of accelerants, disabled smoke detectors, and severed power to the apartment. The defendant was the beneficiary of several life insurance policies on the victims. After her conviction, she pursued multiple avenues of post-conviction relief in both state and federal courts over the next three decades, raising various claims, including ineffective assistance of counsel.After her initial conviction and sentencing in Ada County, the defendant filed her first post-conviction petition, which was denied by the district court. The Idaho Supreme Court affirmed, finding that her trial counsel had conducted reasonable investigation and that she failed to show prejudice. In subsequent years, she filed several more post-conviction petitions in state court and two federal habeas corpus actions, all of which were unsuccessful. Notably, her claim that trial counsel failed to investigate and present evidence of her alleged brain damage was not raised until her second post-conviction petition, which the Idaho Supreme Court found to be untimely under Idaho Code section 19-2719, as the claim could have been raised earlier.The Supreme Court of the State of Idaho reviewed her sixth post-conviction petition, in which she again argued ineffective assistance of trial and post-conviction counsel, and contended that recent federal case law (Shinn v. Ramirez) should allow her to relitigate her claims. The Idaho Supreme Court held that Idaho Code section 19-2719 strictly limits post-conviction claims to those raised within forty-two days of the death sentence, unless the claims were not and could not reasonably have been known. The court concluded that neither changes in federal law nor alleged ineffective assistance of post-conviction counsel excused her untimely filing, and affirmed the district court’s summary dismissal of her petition as time-barred. View "Row v. State" on Justia Law

Police officers responded to a call regarding an individual, McGuire, at a convenience store in Idaho Falls. After determining he was homeless and possibly under the influence, officers took him to a hospital for medical clearance and then to a behavioral health crisis center, where admission is voluntary. When McGuire failed to complete intake paperwork and did not leave when asked, officers attempted to escort him out. A physical altercation ensued, resulting in injuries to both officers. McGuire was charged with felony battery on a law enforcement officer and misdemeanor resisting or obstructing an officer. At trial, the evidence included officer testimony and body camera footage. McGuire did not testify and argued the State had not met its burden of proof.The Seventh Judicial District Court of Idaho denied McGuire’s motion for mistrial, which was based on statements by the prosecutor during closing argument that allegedly shifted the burden of proof to the defendant. The jury found McGuire guilty on both counts. McGuire was sentenced to one year fixed for the felony and fined for the misdemeanor. The Idaho Court of Appeals affirmed both convictions, and McGuire sought further review.The Supreme Court of the State of Idaho reviewed the case, giving due consideration to the Court of Appeals but directly reviewing the trial court’s decisions. The Supreme Court held that there was sufficient evidence to support the conviction for battery on a law enforcement officer, as officers were performing their duties when responding to the crisis center. However, the Court found insufficient evidence to support the conviction for resisting or obstructing an officer, as the State failed to prove the officers’ actions were lawful and authorized under the relevant statute. The Court also held that, although the prosecutor’s comments constituted misconduct, the trial court’s prompt corrective actions and jury instructions cured any resulting error. The Supreme Court affirmed the felony conviction and denial of the mistrial motion, but vacated the misdemeanor conviction. View "State v. McGuire" on Justia Law

Two men, including the defendant, traveled through Idaho seeking welding work. The defendant owned mobile welding equipment, which he allowed his companion to use for practice in a rural area. After helping set up the equipment, the defendant returned to his truck to nap while his companion welded. During this time, a fire ignited, spreading rapidly and causing significant property damage, including the destruction of homes and grassland. Both men were cited for violating Idaho’s statute prohibiting the willful or careless setting of fires on timber or prairie lands.The case proceeded to trial in the Magistrate Court of Power County, where the State presented evidence that the defendant enabled and facilitated the welding activity in dry, windy conditions, and failed to take adequate precautions to prevent fire. The defendant moved for acquittal twice, arguing that he neither directly ignited the fire nor acted with the requisite criminal negligence. The magistrate court denied both motions, and the jury found the defendant guilty. The defendant was sentenced to a suspended jail term, probation, community service, and restitution. On appeal, the District Court of the Sixth Judicial District affirmed the conviction, finding sufficient evidence of carelessness and upholding the jury instructions.The Supreme Court of the State of Idaho reviewed the case, applying a proximate cause standard to the statutory language “cause to be set on fire.” The Court held that the statute requires proof that the defendant’s actions proximately caused the fire and that he acted with criminal negligence, defined as gross negligence or reckless disregard for the safety of others. The Court found sufficient evidence to support the jury’s verdict under this standard and affirmed the district court’s decision upholding the conviction. View "State v. Frias" on Justia Law