Justia Criminal Law Opinion Summaries

Tyler Clapp appealed his conviction for driving under the influence. After stopping Clapp for “spinning cookies” in a parking lot, police became suspicious that Clapp was intoxicated. Clapp refused to submit to any field sobriety tests. Police then obtained a warrant for a blood draw, which showed that Clapp’s blood alcohol content (“BAC”) was 0.152 several hours after initially detaining him. At trial, the State sought to introduce the results of the blood draw. Over Clapp’s objection, the district court allowed the nurse who conducted the blood draw to testify telephonically to his qualifications in order to lay sufficient foundation to admit the results of the blood draw. The results of the blood draw were ultimately admitted, and the jury convicted Clapp of driving under the influence. Clapp appealed. The Idaho Supreme Court found the telephonic testimony violated Clapp’s right to confrontation, "'the face-to-face confrontation requirement is not absolute does not, of course, mean that it may be easily dispensed with. ... [A] defendant’s right to confront accusatory witnesses may be satisfied absent a physical, face-to-face confrontation at trial only where denial of such confrontation is necessary to further an important public policy and only where the reliability of the testimony is otherwise assured.' Both requirements must be met." Further, the Supreme Court determined the State failed to meet its burden establishing harmless error. The conviction was vacated and the matter remanded for further proceedings. View "Idaho v. Clapp" on Justia Law

This appeal consisted of two consolidated cases concerning drug-related charges. Casey Casper appealed his sentence, arguing it was excessive in light of mitigating factors he claimed the district court failed to properly consider. Casper also challenged certain restitution costs awarded to the State, claiming that they were unlawful under a plain interpretation of Idaho Code section 37- 2732(k). After review, the Idaho Supreme Court determined the district court did not abuse its discretion by imposing a ten-year sentence with three years fixed. The Supreme Court affirmed Casper's conviction and the resulting sentence and order of restitution. View "Idaho v. Casper" on Justia Law

Gregory Wade Towner, Sr., appealed his conviction for possession of methamphetamine. The arresting officer found the contraband on Towner’s person during a warrantless search. Towner moved to suppress, arguing that the officer’s conduct violated his constitutional rights against unreasonable search and seizure. The district court denied Towner’s motion after concluding that the officer’s seizure and subsequent search were a reasonable exercise of the officer’s community caretaking function. Towner appealed and the Idaho Court of Appeals affirmed. The Idaho Supreme Court granted Towner’s petition for review, and reversed, finding the trial court erred in concluding the officer's act of taking Towner into protective custody was within the officer’s authority under the community caretaker exception to the Fourth Amendment without considering the requirements of Idaho Code section 66-326(1). The case was remanded with instructions for the trial court to enter findings of fact related to whether the State proved that Towner was “gravely disabled” or an “imminent danger” to himself or others because of his mental illness under Idaho Code section 66-326(1), before he was taken into protective custody. View "Idaho v. Towner" on Justia Law

Defendant-appellant Vincent Brown made two oral requests for reduction of sentence prior to the district court relinquishing jurisdiction and imposing sentence. After sentence was imposed, Brown filed one written motion to reduce sentence pursuant to Idaho Criminal Rule 35(b). The district court denied the motion, and Brown appealed that denial. Before reaching the merits of Brown’s appeal, the Idaho Supreme Court addressed three prior decisions concerning Rule 35(b). The Court disavowed its decision in Idaho v. Wersland, 873 P.2d 144 (1994), and abrogated the holding in Idaho v. Bottens, 52 P.3d 875 (Ct. App. 2002) to the extent those cases treated the one motion limit in Rule 35(b) as jurisdictional in effect. The Court also clarified that the one motion limit in Rule 35(b) was a procedural rule, but the Court applied this announcement only prospectively. In addition, the Court abrogated Idaho v. Hurst, 258 P.3d 950 (Ct. App. 2011) where the Court of Appeals interpreted the one motion limit in Rule 35(b) as applying to both written and oral motions for a reduction of sentence at any point after a sentence is announced. Here, the Court affirmed the district court’s decision denying Brown’s Rule 35(b) motion to reduce his sentence: "Brown did not show that under any reasonable view of the facts, the district court’s sentence is excessive." View "Idaho v. Brown" on Justia Law

In 2006, Timothy Dunlap was sentenced to death by a Caribou County, Idaho jury for the death of a Soda Springs bank teller killed in 1991. In 2008, Dunlap filed a petition for post-conviction relief, alleging that numerous errors had occurred at his 2006 sentencing hearing. The district court dismissed the petition in its entirety. Dunlap appealed to the Supreme Court, which affirmed the dismissal of all but two of Dunlap’s claims: (1) multiple claims of prosecutorial misconduct under Brady v. Maryland, 373 U.S. 83 (1963) and Napue v. Illinois, 360 U.S. 264 (1959); and (2) ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984). Upon remand, the district court held two evidentiary hearings, one involving each of Dunlap’s remaining claims. The district court found that Dunlap had failed to establish either claim and denied Dunlap’s request for post-conviction relief. Dunlap timely appealed. Finding no reversible error in these decisions, the Idaho Supreme Court affirmed the district court. View "Dunlap v. Idaho" on Justia Law

Adam Paulson was arrested for misdemeanor driving under the influence (DUI) at the scene of the accident; he struck and killed a pedestrian with his vehicle as the pedestrian was crossing a road on a late November 2017 night. He was later charged with vehicular manslaughter, and a jury trial was held in October and November 2018. The jury convicted Paulson of vehicular manslaughter. Paulson appealed his conviction, arguing the district court erred when it refused to instruct the jury on the causation element required by Idaho Code section 18- 4006(3)(b). Paulson argued the district court should have instructed the jury regarding proximate, intervening, and superseding causes because the pedestrian, who was intoxicated, crossed the road in an unlit area with no marked crosswalk. Paulson also contended his right to a fair trial was violated when the district court instructed the jury using Idaho Criminal Jury Instruction (ICJI) 709, arguing that ICJI 709 did not set forth all the elements of Idaho Code section 18-4006(3)(b). After review, the Idaho Supreme Court found the district court erred in declining to instruct the jury on the required causal link between a defendant’s unlawful conduct and the victim’s death. The Court also found the district court erred in refusing to instruct the jury on whether the pedestrian’s conduct constituted an intervening, superseding cause and on a pedestrian’s duties when walking along roadways. The Supreme Court vacated Paulson's vehicular manslaughter conviction; the case was remanded for further proceedings. View "Idaho v. Paulson" on Justia Law

Defendant-appellant Corey McGrath was charged with two counts of lewd conduct with a minor: one regarding his five-year-old stepdaughter, B.B.; and one regarding his twelve-year-old stepdaughter, L.N. The two counts were severed for trial. During a jury trial on the first count, and over McGrath’s objection, the State introduced evidence of McGrath’s cell phone internet search history, which included searches for stepfather-stepdaughter themed pornography, along with two still images of pornographic videos purportedly viewed by McGrath. The jury convicted McGrath of one count of lewd conduct with respect to B.B. McGrath subsequently, pursuant to a plea agreement, pleaded guilty to felony injury to a child regarding L.N.’s accusations in the second count. McGrath was sentenced to life in prison with twenty years fixed for the lewd conduct charge, and ten years fixed for the felony injury to a child charge. The sentences were ordered to run concurrently. McGrath appealed his conviction of lewd conduct and the sentences imposed for both convictions. The Idaho Court of Appeals affirmed McGrath’s convictions and sentences. Finding no reversible error, the Idaho Supreme Court likewise affirmed McGrath's convictions and sentences. View "Idaho v. McGrath" on Justia Law

Defendant-appellant Danielle Guerra appealed a district court’s decision affirming a judgment of conviction for driving under the influence of drugs (“DUI”). Guerra contended the magistrate court erred when it denied her motion to set aside the jury verdict under Idaho Criminal Rule 29 or, in the alternative, grant a new trial under Idaho Criminal Rule 34. Further, Guerra argued the magistrate court erred when making a number of evidentiary rulings. The district court, acting in its appellate capacity, affirmed the magistrate court’s rulings and judgment of conviction. The Idaho Supreme Court found the district court erred when it upheld the magistrate court’s ruling permitting the arresting officer to testify about the motor vehicle warning on Guerra’s medication bottles. The pill bottles found in Guerra’s car were not offered or admitted into evidence. The officer testified to three warnings or “signs” on the medication bottles. The Court found that the inclusion of a warning on a medication bottle to “take due caution when operating a motor vehicle or heavy equipment” was more than just an admonishment: "The warning impliedly asserts that the medication in the bottle may impair the user’s ability to drive a car or use heavy equipment. Because this warning constitutes an assertion of fact that is capable of being proven true (i.e., the medication may impair the ability to drive), Officer DeLeon’s testimony concerning that warning constituted an assertion of fact and is subject to the hearsay rules." The Supreme Court concluded the State failed to carry its burden of demonstrating a proper non-hearsay purpose for the motor vehicle warning evidence. "The harmfulness of allowing Officer DeLeon’s testimony about the warning to come in for the truth of the matter asserted is evidenced in the statements of multiple jurors during voir dire in response to the prosecutor’s questions related to taking prescription medications while driving." Judgment was affirmed in part, reversed in part, and remanded the case to the district court with instructions to vacate the judgment of conviction and remand the case to the magistrate court for further proceedings. View "Idaho v. Guerra" on Justia Law

A grand jury indicted defendant-appellant Jordan Spencer for three counts of felony trafficking in heroin, one count of felony possession of methamphetamine, one count of felony possession of bath salts with intent to deliver, and one count of misdemeanor possession of drug paraphernalia. After a jury trial, Spencer was found guilty on all counts. Spencer appealed two of the six counts of which he was convicted, arguing there was insufficient evidence to sustain his conviction on one count of trafficking in heroin, and that the district court erred when it admitted the out-of-court statements of the State’s confidential informant because those statements violated his Sixth Amendment right to confront witnesses. The Idaho Supreme Court vacated Spencer's conviction on Count I, finding it was not supported by substantial evidence on which the jury could conclude the prosecution proved all essential elements beyond a reasonable doubt. The Court affirmed Spencer’s conviction of trafficking heroin as charged in Count II. View "Idaho v. Spencer" on Justia Law

Defendant-appellant was convicted by jury of domestic battery, attempted strangulation, and aggravated assault. He appealed to the Idaho Court of Appeals, which affirmed his convictions. Reyes petitioned for review by the Idaho Supreme Court, which was granted. On appeal, Reyes requested his convictions be vacated, arguing: (1) several evidentiary issues, including the admission of irrelevant and prejudicial evidence, rendered his trial unfair; (2) the district court abused its discretion when it found that the victim was unavailable to testify at trial under Idaho Rule of Evidence 804(a)(5) and allowed her preliminary hearing testimony to be read into the record; (3) the prosecutor’s closing argument impermissibly implied that the victim did not testify because she feared Reyes; and (4) these errors, when taken together, deprived him of his right to due process and a fair trial. After review, the Supreme Court found the district court erred when it determined the victim was unavailable to testify at trial, and allowed her preliminary hearing testimony to be read into the record. Further, the Court concurred the prosecutor's comment that the victim was "probably scared" to testify at trial was improper. In the aggregate, the Court concluded these errors rendered the trial unfair. Accordingly, Reyes' conviction was reversed and the case remanded for a new trial. View "Idaho v. Reyes" on Justia Law