Justia Criminal Law Opinion Summaries

Following the State’s dismissal of criminal charges against him, Nickolaus Oldenburg moved the district court to seal the criminal court file pursuant to Idaho Code section 67-3004(10). The State did not contest the motion. Nevertheless, the district court concluded that it did not have the authority to seal Oldenburg’s case file under section 67-3004(10) and, therefore, could not grant his request. As a result of its analysis, the district court denied Oldenburg’s motion. The Idaho Supreme Court held the district court correctly concluded that the legislature could not independently vest the district court with the authority to seal Oldenburg’s court file. "The control of court records resides within the prerogative of this Court, and this Court has adopted I.C.A.R. 32 to govern a defendant’s request to seal court records. ... When the statute is procedural, it is viewed as an attempt 'to control this Court’s processes' and is classified as an impermissible overreach into the authority of this Court to develop its own procedures." Thus, the district court correctly found that Idaho Code section 67-3004(10) impinged on the Supreme Court’s prerogative to make its own rules which governed its own procedure. Accordingly, the decision of the district court was affirmed. View "Idaho v. Oldenburg" on Justia Law

Rodney Harrell appealed his conviction for trafficking in methamphetamine, trafficking in marijuana, and possession of drug paraphernalia. Harrell argued his convictions should have been vacated because: (1) the district court erred in denying his motion to suppress; and (2) the district court erred in denying his objection to the reduction of peremptory challenges imposed by the Idaho Supreme Court’s emergency order adopted in response to the COVID-19 pandemic. Finding no reversible error, the Supreme Court affirmed Harrell’s judgment of conviction. View "Idaho v. Harrell" on Justia Law

While a passenger during an unrelated traffic stop, defendant-appellant Audrey Monroe was recognized by a Bingham County Sheriff’s deputy as having an outstanding warrant. Pursuant to the warrant, the deputy attempted to take her into custody. In the course of the arrest, Monroe refused to release her phone, which was secured on her finger by a phone ring holder. As Monroe’s resistance escalated, she fell to the ground and began violently kicking, making contact with the officer. Ultimately, she was secured in the police cruiser. The incident was captured on video by the arresting officer’s body camera. For her conduct during the arrest, Monroe was charged with felony battery on a police officer. During trial, Monroe asked the district court for jury instructions regarding two misdemeanor offenses, asserting that they were lesser included offenses of the crime charged. The district court declined to give either instruction. At the conclusion of the trial, the jury found Monroe guilty of the felony charge. On appeal, Monroe argued the district court erred in failing to give the requested lesser included jury instructions. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Monroe" on Justia Law

While on patrol, Deputy Sheriff Brock Katseanes discovered an unattended car parked in the parking lot of a public boat launch. The car was unlocked, and its trunk and front windows were open. Katseanes learned the car was registered to April Ramos. Katseanes was eventually joined by five additional officers and a canine to search the surrounding area for Ramos, but they were unsuccessful in locating her. Due to his previous encounters with Ramos, Katseanes believed the car likely contained illegal drugs. The canine conducted a drug sniff; the dog did not alert during its sniff of the car’s exterior. The officers subsequently impounded the car and then conducted an inventory search of it prior to having the car towed. During the inventory search, the officers found methamphetamine and drug paraphernalia. Ramos was charged with possession of a controlled substance and possession of drug paraphernalia. She moved to suppress all evidence found during the inventory search of the car. The district court denied her motion. Ramos conditionally pleaded guilty to possession of a controlled substance but retained her right to appeal the denial of her motion to suppress. As a result of the plea agreement, the State dismissed the possession of drug paraphernalia charge. Ramos timely appealed, and the Idaho Court of Appeals affirmed. The Idaho Supreme Court reversed the district court's judgment. "Absent clear instruction from the United States Supreme Court, we decline to expand Opperman’s 'community caretaking' rationale to include potential theft or property damage to the vehicle as an acceptable reason to impound a vehicle. ... an officer’s concern that the car will be subject to theft or property damage if it is not impounded—no matter how well-founded the concern may be—is irrelevant to the analysis as to whether the decision to impound the car is reasonable under the Fourth Amendment." The case was remanded to the district court to determine whether the decision to impound Ramos’s car passed constitutional muster. View "Idaho v. Ramos" on Justia Law

Edo, a dog used by the Boise Police Department to detect controlled substances, alerted on defendant-respondent Shawna Pendleton’s vehicle during a traffic stop. Videos of the incident raised questions about the reliability of Edo’s performance. Through a series of discovery requests, Pendleton sought additional videos and police reports from past stops to challenge Edo’s reliability in detecting drugs. The district court, over repeated objections from the State, ultimately granted her motion to compel the evidence on finding it material to her defense. On appeal, the State argued the district court abused its discretion by denying its motion for reconsideration because: (1) Pendleton failed to establish that the requested evidence was material to her defense; (2) the production of four-months’ worth of Edo’s reports and videos was unduly burdensome, and (3) not all of the requested evidence was within the prosecutor’s possession, custody, or control. The Idaho Supreme Court concluded the State failed to show an abuse of discretion in compelling production of the videos and reports regarding Edo and his handler for the four months prior to Pendleton’s arrest. The Supreme Court affirmed the district court’s determination that the evidence sought by Pendleton was material, not unduly burdensome, and in the “possession, custody or control” of the prosecution pursuant to Idaho Criminal Rule 16. View "Idaho v. Pendleton" on Justia Law

In 2017, Guy Bracali-Gambino pleaded guilty to possession of major contraband in a correctional facility. On direct appeal, the Idaho Court of Appeals, in an unpublished opinion, affirmed his conviction and sentence. Bracali-Gambino subsequently filed a petition for post-conviction relief, arguing in relevant part that his trial counsel had coerced him into pleading guilty, provided erroneous legal advice regarding sentencing enhancements for persistent violators, and failed to investigate the prosecution’s evidence. Bracali-Gambino contended, that considering these errors, his trial counsel had been ineffective. Except for a portion of one of Bracali-Gambino’s claims (Claim II), the district court summarily dismissed his claims relevant to this appeal without conducting an evidentiary hearing. The district court also ultimately dismissed the one remaining claim following an evidentiary hearing. The Idaho Supreme Court affirmed the district court’s dismissal of Bracali-Gambino’s petition for post-conviction relief. Claim II failed because Bracali-Gambino specifically disclaimed, while under oath at his change of plea hearing, that anyone (which included his defense counsel) had coerced or pressured him into pleading guilty. Claim III failed because Bracali-Gambino’s conclusory allegations were not sufficient to show that he was prejudiced by the purported erroneous legal advice. Finally, Claim VI failed because Bracali-Gambino did not provide a sufficient explanation as to how certain testimony would have contradicted the State’s evidence that he attempted to possess major contraband. View "Bracali-Gambino v. Idaho" on Justia Law

After methamphetamine was found on his person during a pat search, Appellant John Doe was charged with felony possession of a controlled substance and two related misdemeanors under the Juvenile Corrections Act (“JCA”). Doe moved to suppress this evidence as the product of an unlawful search under the Fourth Amendment, which the magistrate court denied. Doe then sought permission to appeal the magistrate court’s decision to the district court, sitting in its intermediate appellate capacity. When the magistrate court denied permissive appeal, an intermediate appeal was filed with the district court. The district court dismissed Doe’s appeal, concluding that a permissive appeal was not available to Doe because he had not yet been adjudicated of any violation under the JCA. Doe then appealed to the Idaho Supreme Court, arguing: (1) he was “within the purview” of the JCA; and (2) Idaho Code section 20-528 permitted an appeal as a matter of right to a juvenile defendant whose motion to suppress has been denied. The Idaho Supreme Court concluded the plain language of the statute did not permit a juvenile defendant to file this type of interlocutory appeal. Accordingly, the Court affirmed the district court’s dismissal of John Doe’s interlocutory appeal. View "Idaho v. John Doe" on Justia Law

An Idaho district court denied Jared Head’s motion to strike certain evidence supporting a restitution order. Jared and his wife, Teresa, worked as onsite managers at the Village Inn Motel in Malad City, Idaho. Following an investigation by the Oneida County Sheriff’s Office, Jared and Teresa were separately charged with grand theft. After pleading guilty to grand theft, Jared was ordered to pay $24,535.23 in restitution for allowing people to stay at the motel without paying, and for accepting rent payments that he did not relinquish to the motel owners. Relevant to this appeal, some of the State’s evidence supporting the restitution amount related to a specific hotel guest, S.G. Just before resting its case at the restitution hearing, the State disclosed that S.G. had been found incompetent to stand trial in an unrelated criminal case several months earlier. Jared then sought to strike any testimony, exhibits, and statements related to S.G., arguing the State withheld exculpatory evidence in violation of his due process rights under Brady v. Maryland, 373 U.S. 83 (1963) and in violation of his Sixth Amendment right to confrontation under Crawford v. Washington, 541 U.S. 36 (2004). The district court denied Jared’s motion after concluding that his due process claim was moot because Brady did not apply to restitution hearings, which the district court couched as civil proceedings. Jared appealed, arguing the district court erred in applying an incorrect legal standard to deny his motion to strike. Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Idaho v. Head" on Justia Law

In 2019, Officer Pallas was off duty and not in uniform when he noticed defendant-respondent Jonathan Bell at an Albertsons grocery store in Hailey, Idaho. Bell appeared to be unsteady on his feet, was having difficulty walking, and appeared confused. As Pallas watched Bell get into the driver’s seat of his vehicle and begin to drive, he called Officer Murphy, who was Pallas’ training officer and on duty, to report Bell as possibly driving under the influence. Murphy told Pallas to call dispatch, which he did. Pallas gave dispatch a description of the vehicle, the license plate number, and reported that the driver appeared to be intoxicated. The issue this case presented for the Idaho Supreme Court's review centered on the scope of its holding in Idaho v. Clarke, 446 P.3d 451 (2019). There, the Court held that an individual could not be arrested without a warrant for a misdemeanor that was completed outside the arresting officer’s presence. The State of Idaho argued that the “in the presence of the arresting officer” requirement under Clarke could be satisfied by the collective knowledge of more than one officer to establish probable cause. Thus, though the arresting officer here did not witness Bell’s driving pattern for the DUI, the State argued he had sufficient “collective knowledge” from others to carry out the arrest. The magistrate court agreed with this position below and denied Bell’s motion to suppress. However, Bell appealed to the district court, which reversed the magistrate court’s decision, concluding that the Idaho Constitution prohibited a police officer from making a warrantless arrest for a DUI committed outside the officer’s presence, even if the officer had probable cause for that offense through his collective knowledge from another officer. Finding no reversible error in that decision, the Supreme Court affirmed the district court’s decision. View "Idaho v. Bell" on Justia Law

Defendant-appellant Robert Miller appealed his conviction for felony driving under the influence (“DUI”) and the district court’s application of a sentencing enhancement based on a prior conviction for felony DUI within the previous fifteen years. On appeal, Miller argued: (1) the district court erred in dismissing the jury before it heard and determined the facts regarding the sentencing enhancement without first obtaining a valid waiver of Miller’s right to a jury trial; (2) the appropriate remedy for the error was to determine the sentencing enhancement did not apply; and (3) if the sentencing enhancement was still applicable to Miller, his sentence should be vacated and the case remanded for a new trial on whether Miller should be subject to the sentencing enhancement. Given the State’s concession that the district court committed fundamental error, the Idaho Supreme Court concluded the appropriate remedy was to vacate Miller’s sentence and remand for a new trial to determine whether the sentencing enhancement applied to Miller. View "Idaho v. Miller" on Justia Law