Justia Criminal Law Opinion Summaries

Defendant-appellant Desiree Karst appealed a district court’s partial denial of her motion to suppress evidence obtained during a traffic stop. Karst argued on appeal that the police sergeant impermissibly extended the traffic stop when he briefly interrupted his traffic-related investigation to contact dispatch and request a drug-dog unit at the scene. The Court of Appeals affirmed the district court’s decision, citing its recent decision in Idaho v. Still, 458 P.3d 220 (Ct. App. 2019). The Idaho Supreme Court granted Karst’s petition for review, overruled Still, reversed the district court’s decision, and remanded for further proceedings. The Supreme Court found that an unlawful extension of a traffic stop occurs when an officer’s detour prolongs, or adds time to, the original purpose for the stop. The Court of Appeals’ decision in Still improperly required “abandonment” of the traffic mission for a stop to become unlawfully extended. Here, the Court found the arresting sergeant indeed impermissibly extended the duration of the traffic stop when he requested the drug- dog unit, in violation of the Fourth Amendment. View "Idaho v. Karst" on Justia Law

Defendant Mark Wilson was charged with unlawful possession of a firearm in violation of Idaho Code section 18- 3316. The charge also carried with it a persistent violator sentencing enhancement. In a bifurcated trial, a jury first found Wilson guilty of unlawful possession of a firearm. The jury then found Wilson subject to an enhanced sentence due to his status as a persistent violator. Wilson appealed to the Idaho Court of Appeals, arguing that the State had failed to present sufficient evidence that he had been convicted of at least one previous felony at the time he possessed a firearm. Wilson also argued that the State failed to present sufficient evidence that he had been convicted of two prior felonies (an essential prerequisite of the persistent violator enhancement). The Court of Appeals affirmed Wilson’s convictions. Finding no reversible error, the Idaho Supreme Court affirmed Wilson’s convictions. View "Idaho v. Wilson" on Justia Law

Defendant-appellant Jennifer Olsen contended the application of withheld judgments in Idaho violated Idaho Code section 19-2601 because it caused criminal defendants to be convicted, thereby negating the legal benefits envisioned by the statute. Olsen was charged with misdemeanor driving under the influence, first offense. She entered into a plea agreement with the State, but later asked the magistrate court to not accept her guilty plea and grant her a “true” withheld judgment instead—i.e., one by which no conviction would take place . The magistrate court denied her motion, accepted her guilty plea, and granted her a withheld judgment. As part of the withheld judgment, the magistrate court: placed Olsen on supervised probation for 12 months subject to certain conditions, including: a requirement that she pay a fine and court costs; that her driving privileges be suspended for 180 days; that an interlock system be installed in her car; and that she attend Court Alcohol School and the Victim’s Impact Panel. Olsen appealed the magistrate court’s denial of her request for a “true” withheld judgment, and contented that court’s grant of a withheld judgment was not appropriately applied or effectuated. Finding no reversible error in the magistrate court’s judgment, the Idaho Supreme Court affirmed. View "Idaho v. Olsen" on Justia Law

Paul Stonecypher was stopped by law enforcement for vehicle equipment violations while driving through Idaho on a trip from California to Montana. Stonecypher contended his seizure was unlawfully prolonged to allow for a sniff of the vehicle by a drug-detection dog. After review of the trial court record, the Idaho Supreme Court disagreed, finding the extension of the stop was justified by reasonable suspicion of illegal drug activity. View "Idaho v. Stonecypher" on Justia Law

In September 2018, Customs and Border Protection (“CBP”) officers arrested Darren Temple in California as he crossed the border from Mexico into the United States. Temple had been in Mexico for legitimate business purposes, but CBP officers received a positive alert for his name from the National Crime Information Center indicating that Temple was wanted in Idaho on an outstanding warrant for lewd and lascivious conduct with a minor. Prior to his arrest, Temple had filed for a divorce from Jennifer Temple in March 2018. Then, in May 2018, Jennifer’s daughter, J.P., filed a report with the Canyon County Sheriff’s Office alleging that Temple, her then stepfather, had sexually abused her. Though J.P. did not report the sexual abuse to law enforcement for some time, she testified that she had told her best friend, her boyfriend, and her mother, Jennifer, immediately following the last incident of sexual abuse in late November 2014. After encouragement from her therapist, J.P. eventually reported the incident to law enforcement in May 2018. Two days after his CBP arrest, Idaho charged Temple with one count of lewd conduct with a minor under sixteen. Under the case caption and case number of his criminal case, Temple served Jennifer’s divorce attorney with a subpoena duces tecum seeking “any and all documents related to the billing and payment records related to the representation of Jennifer Temple, to include, but not limited to the number of hours worked and the number of hours charged.” Jennifer’s attorney moved to quash the subpoena , arguing the requested records contained attorney-client privileged information and attorney work product. Temple did not respond to the motion to quash his subpoena. The district court granted the motion to quash, concluding the information sought was irrelevant and, alternatively, covered by the attorney-client privilege. Temple appealed the subpoena issue to the Idaho Supreme Court. Finding no reversible error in the decision to quash, the Supreme Court affirmed. View "Idaho v. Temple" on Justia Law

The State challenged a district court’s order denying a motion to exclude expert testimony that defendant-respondent Ruben Diaz lacked the mens rea to commit aggravated battery because he suffered from a mental illness or defect that caused him to believe the victim was not a person but instead an alien being from another planet. The State charged Diaz with aggravated battery, use of a deadly weapon in the commission of a crime, and resisting and obstructing a police officer after he stabbed a man in a random attack. The State filed a motion in limine to exclude Diaz’s expert testimony, arguing Idaho Code section 18-207 barred expert testimony on evidence of a mental condition. The district court denied: (1) the motion in limine; (2) the State’s subsequent motion to reconsider; and (3) the State’s motion for a permissive appeal. The State then timely filed a motion for permissive appeal to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Diaz" on Justia Law

Talon Ross appealed a district court’s order revoking his probation and imposing his previously suspended sentence for a robbery he pleaded guilty to in 2011. In 2019, Ross was charged with violating the terms of his probation by allegedly committing petit theft and injury to a child. At an evidentiary hearing on the probation violation allegations, the district court found that, despite Ross introducing a judgment of acquittal for the petit theft charge, the State had proved by a preponderance of the evidence that Ross had committed petit theft. Additionally, the district court found by a preponderance of evidence that Ross had committed injury to a child. The Idaho Court of Appeals affirmed the district court’s order revoking Ross’s probation and imposing his sentence. While the Idaho Supreme Court determined the district court did not err in concluding Ross committed the crime of petit theft by a preponderance of the evidence, district court erred in concluding Ross committed injury to a child by a preponderance of the evidence. Judgment was reversed and the matter remanded for a new probation violation hearing. View "Idaho v. Ross" on Justia Law

Aaron Tower appealed a district court’s order denying his motion to suppress evidence obtained following a warrantless arrest. In 2018, Tower’s mother, Michelle, contacted the Boise Police Department (BPD) and spoke to Officer Hilton to report that her son, Tower, had threatened to “blow his head off in [her] house.” The State also alleged that Tower posted on social media that he was driving from Nevada to Idaho with a plan to shoot Michelle and his stepfather. Michelle was out of town at the time. Tower’s grandmother, Sandra, was at home, however, because she was watching the house while Michelle was away. Michelle told Officer Hilton she was concerned for Sandra’s safety and said she did not want Tower on her property. Tower was charged with possession of a controlled substance and with resisting or obstructing an officer. Tower moved to suppress on the grounds the evidence was fruit of an unlawful seizure not based on probable cause. At the hearing on Tower’s motion, Dustin and Michelle both testified. Dustin testified to telling Tower he was under arrest for trespassing, and subsequently placing him under arrest for resisting and obstructing after Tower resisted Dustin’s efforts to handcuff him. Tower argued he was unlawfully arrested for trespassing without probable cause or a warrant, thus, the evidence obtained during a subsequent search should have been suppressed. The Idaho Court of Appeals affirmed his conviction. Tower then petitioned the Idaho Supreme Court for review. The Supreme Court affirmed the district court's decision denying Tower's motion to suppress because Tower did not properly preserve his argument on appeal. View "Idaho v. Tower" on Justia Law

Alejandra Ochoa was convicted by jury of misdemeanor vehicular manslaughter. She appealed her conviction to the district court, which vacated the judgment of conviction and remanded the case for a new trial. The district court held that the magistrate court erred in excluding certain toxicological evidence, refusing to grant defendant’s request to continue the trial, and allowing the State’s pathologist to testify. The State appealed the district court’s decision. The Idaho Supreme Court determined the district court erred in reversing the magistrate court’s decision to not admit the results of the toxicology report, and erred in reversing the magistrate court's denial of the motion for a continuance. Further, the Court found the district court erred in reversing the magistrate court’s decision to allow the forensic pathologist to testify concerning the cause of death. The case was remanded to the district court with instructions to reinstate Ochoa's judgment of conviction. View "Idaho v. Ochoa" on Justia Law

Michael McDermott appealed his conviction for second-degree murder. McDermott arrived at his ex-girlfriend’s home late at night in the hopes of obtaining methamphetamine. After finding another man, Robert Waholi, inside the ex-girlfriend’s recreational vehicle (“RV”), McDermott slammed his ex-girlfriend’s head twice in her front door, causing her to fall. McDermott exited the RV and then, a few moments later, Waholi came out carrying a large double-edged axe. McDermott shot Waholi through the heart, killing him. McDermott eventually confessed to the police that he had killed Waholi; however, he claimed he was acting in self-defense. The Idaho Supreme Court determined the district court erroneously instructed the jury on the concept of malice, rendering McDermott's trial unfair. The conviction was vacated, and the case remanded for a new trial. View "Idaho v. McDermott" on Justia Law