Justia Criminal Law Opinion Summaries

Justin Loera was convicted for battery on a correctional officer. Loera claimed the district court erred in three respects: (1) by partially quashing his subpoena duces tecum based on its relevance rather than the standards prescribed in Idaho Criminal Rule 17(b); (2) for ordering restitution without sufficient evidence; and (3) by failing to address his request for credit for time served. After review of the facts specific to this case, the Idaho Supreme Court affirmed the district court’s decision to partially quash Loera’s subpoena duces tecum. However, the Court vacated the district court’s order awarding restitution and remanded the case with instructions for the court to award Loera 202 days of credit for time served. View "Idaho v. Loera" on Justia Law

Brandon Lynn Winkler appealed a district court order denying his motion to dismiss a January 2019 felony charge for driving under the influence of alcohol. Despite Winkler having been pardoned for a 2006 felony DUI, the district court determined that it still counted as a prior felony DUI for purposes of charging Winkler with a felony under Idaho Code section 18-8005(9). On appeal, Winkler argued the district court erred in concluding that a pardon did not prevent a prior felony DUI from being used to enhance a subsequent DUI charge to a felony under Idaho Code section 18-8005(9). The Idaho Supreme Court concurred: the district court erred in allowing Winkler's prior DUI conviction to be used to enhance his pending DUI charge. As such, the order was reversed and the matter remanded for further proceedings. View "Idaho v. Winkler" on Justia Law

Law enforcement used confidential informants to make several purchases of controlled substances from Darius Haws and his brother between April and May of 2015. While out on bond, Haws went to the residence of a female acquaintance. The woman called the police to report that Haws was trespassing. As a responding law enforcement officer approached Haws, the officer could “smell a strong odor of alcohol coming from [Haws’] breath.” When the officer attempted to arrest Haws, Haws resisted, swinging his arm and hitting the officer. Based on this altercation, the State charged Haws with battery on a police officer, resisting and obstructing an officer, criminal trespass, and disturbing the peace. Haws’ guilty pleas were entered pursuant to plea agreements in which he waived his right to appeal his convictions or sentences. The district court sentenced Haws to two years fixed, with four years indeterminate, for the delivery charge; and one year fixed, with three years indeterminate, for the battery charge. The sentences were ordered to run consecutively. Initially, the district court retained jurisdiction over Haws, but after performing poorly during the period of retained jurisdiction, the district court relinquished jurisdiction and ordered the original sentences be served. On appeal, Haws argued the district court abused its discretion in relinquishing jurisdiction and that his sentences were excessive. In response, the State sought to have Haws’ appeal dismissed because Haws expressly waived his right to appeal his sentences in the plea agreements he signed. The Court of Appeals agreed, dismissing Haws’ challenge to his sentences and affirming the district court’s decision to relinquish jurisdiction over Haws. On appeal to the Idaho Supreme Court, Haws contended the Court of Appeals incorrectly held that he had forfeited the right to address the validity of his plea agreements by not raising an issue of validity of those waivers in his opening brief. Instead, Haws contended it was the State’s obligation to assert the applicability of the appellate waiver, and that he should have had the opportunity to respond in his reply brief. Additionally, Haws argued his appellate waiver was not made knowingly, intelligently, and voluntarily because the district court made a statement that conflicted with the written plea agreements by noting that Haws had the right to appeal his sentences. The Supreme Court found no reversible error and affirmed the district and appellate courts. View "Idaho v. Haws" on Justia Law

Cari Oxford was convicted by jury of second degree kidnapping after she kidnapped her neighbor’s infant son. On appeal, Oxford contended the district court abused its discretion in: (1) denying her the funds necessary to retain an expert witness to assist with her defense; (2) refusing to allow the doctor who examined her for purposes of her competency evaluation to testify at trial regarding her mental health condition; and (3) ordering restitution without any evidence supporting it. Finding no reversible error as to her conviction, the Idaho Supreme Court affirmed. However, the restitution order was not supported by substantial evidence, so that order was vacated. View "Idaho v. Oxford" on Justia Law

Darius Haws appealed after he pled guilty to delivery of a controlled substance and battery on a police officer pursuant to plea agreements in which he waived his right to appeal his convictions or sentences. The district court sentenced Haws to two years fixed, with four years indeterminate, for the delivery charge; and one year fixed, with three years indeterminate, for the battery charge. The sentences were ordered to run consecutively. Additionally, the district court retained jurisdiction over Haws. However, after Haws performed poorly during the period of retained jurisdiction, the district court relinquished jurisdiction over Haws and ordered that the original sentences be served by Haws. Haws appealed, arguing that the district court abused its discretion in relinquishing jurisdiction and that his sentences were excessive. In response, the State sought to have Haws’ appeal dismissed because Haws expressly waived his right to appeal his sentences in the plea agreements he signed. The Court of Appeals dismissed Haws' challenge to his sentences and affirmed the district court's decision to relinquish jurisdiction. Haws appealed to the Idaho Supreme Court, arguing the appellate court erred in finding he forfeited his right to address the validity of his plea agreements. Haws contended that it was the State’s obligation to assert the applicability of the appellate waiver, and that he should have had the opportunity to respond in his reply brief. Additionally, Haws contended his appellate waiver was not made knowingly, intelligently, and voluntarily because the district court made a statement that conflicted with the written plea agreements by noting that Haws had the right to appeal his sentences. Finding no reversible error in the appellate's or trial court's decisions, the Supreme Court affirmed. View "Idaho v. Haws" on Justia Law

In December 2017, Klaus Nico Gomez-Alas was charged with two felony counts: rape and infamous crime against nature. At trial, he was acquitted of rape, but convicted of simple battery as an included offense. On the second count, the jury found Gomez-Alas guilty of an infamous crime against nature. After the verdict, Gomez-Alas moved the district court for a new trial pursuant to Idaho Criminal Rule (I.C.R.) 34, arguing the district court misled the jury by giving an improper “dynamite” instruction. Gomez-Alas also moved the district court for judgment of acquittal on the second count pursuant to I.C.R. 29, arguing there was insufficient evidence to support a conviction for the infamous crime against nature charge. The district court denied both post-trial motions. Gomez-Alas argued on appeal to the Idaho Supreme Court: (1) the act of cunnilingus does not constitute an infamous crime against nature under Idaho Code sections 18-6605 and 18-6606; (2) there was insufficient evidence to support a conviction for the infamous crime against nature charge; and (3) the district court misled the jury by providing an improper dynamite instruction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Gomez-Alas" on Justia Law

Defendant-respondent Jennie Pylican moved to suppress evidence she unlawfully possessed methamphetamine and drug paraphernalia on the evening of October 12, 2017. At that time, an officer observed Pylican enter a storage facility after hours. When she left, the officer followed and observed her make a turn without signaling. Pylican was initially stopped for the traffic violation and later questioned about her presence in a storage facility after hours. The district court granted the motion, holding that the arresting officer unconstitutionally extended the stop when he questioned Pylican regarding her presence in the storage facility. In the alternative, the district court ruled that the officer unconstitutionally extended both the scope and duration of the seizure by requiring Pylican to exit her car. In an unpublished opinion, the appellate court affirmed the district court’s order granting Pylican’s motion to suppress, holding that the officer did not provide any evidence of suspicious activity at the storage facility that would justify Pylican’s extended detention on that basis. On appeal to the Idaho Supreme Court, the State argued the district court erred in grantion Pylican's motion because: (1) the deputy had reasonable suspicion to question Pylican regarding her presence in the storage facility; and (2) the deputy’s order to exit the vehicle did not unconstitutionally extend the duration of the stop. After review of the district court record, the Supreme Court reversed the district court’s order and remanded for further proceedings. View "Idaho v. Pylican" on Justia Law

In September 2018, Idaho State Police Sergeant Curt Sproat pulled over a vehicle driven by defendant-respondent Cody Hansen on Interstate 90 after observing a traffic infraction. As Sergeant Sproat approached the vehicle on the passenger side, he saw a passenger in the back seat making “furtive movements.” Sergeant Sproat asked Hansen for his license and registration and requested identification from the passengers. Hansen provided his license, but informed Sergeant Sproat that he had not yet registered the vehicle and did not know his home address. He also told Sergeant Sproat that he was on felony probation. Hansen declined to give consent to Sergeant Sproat to search the vehicle. After his conversation with Hansen, Sergeant Sproat attempted to contact Hansen’s probation officer, but she was not available. Unable to get ahold of an on-call probation officer, Sergeant Sproat began drafting a citation. After a discussion with another Idaho State Police trooper, Sergeant Sproat decided to search the vehicle. During the search, Sergeant Sproat found a digital scale, a methamphetamine pipe, and eight “dime” baggies of what appeared to be methamphetamine. Based on the contraband found in the vehicle, Sergeant Sproat arrested Hansen. A grand jury indicted Hansen for possession with intent to deliver a controlled substance in violation of Idaho Code section 37-2732(a)(1)(A). Hansen moved to suppress all evidence found in the vehicle, arguing, among other things, that his vehicle was searched without a warrant in violation of the Fourth Amendment of the United States Constitution and Article I, section 17 of the Idaho Constitution. The State appealed when the district court granted Hansen’s motion to suppress. The district court determined that Hansen effectively revoked the consent to be searched he had given as a condition of his probation. The Idaho Supreme Court reversed, finding Hansen never sought to modify the Fourth Amendment waiver term of his probation agreement with the court that granted him probation. Instead, Hansen refused to provide Sergeant Sproat with consent to search his vehicle during the traffic stop. "Even assuming that Hansen intended to revoke the previously agreed to consent in his probation agreement, such an attempt was ineffective because it was not made in court. Accordingly, we conclude that the district court erred in finding that Hansen revoked the consent to be searched provided for in his probation agreement." View "Idaho v. Hansen" on Justia Law

Nicole Lyn Gneiting appealed her conviction for possession of major contraband within a correctional facility under Idaho Code section 18-2510(3). Police responded to a call to a potential burglary at an Idaho Falls motel. They eventually questioned Gneiting, who said she was not staying there, but visiting a friend who was. Officers found a "hard bulgy object" on Gneiting's upper thigh after a pat down search. The object turned out to be a flashlight. A search of the motel room netted a purse containing marijuana, Xanax and Adderall pills. Gneiting was ultimately placed under arrest and taken to the station. When asked whether she had anything illegal on her person, and after given warnings that if she took anything illegal into the jail, she Gneiting would receive an additional charge. Police suspected Gneiting was still carrying something underneath her clothes; she was strip searched and police found a white paper envelope between Gneiting's legs. The envelope was later determined to contain three small plastic bags totaling over 30 grams of methamphetamine. Gneiting was convicted by a jury after a four-day trial on drug possession charges. On appeal, Gneiting argued the State failed to present sufficient evidence to prove beyond a reasonable doubt that she knowingly possessed contraband within a correctional facility because she did not enter the county jail voluntarily. Finding no reversible error, the Idaho Supreme Court affirmed Gneiting's conviction. View "Idaho v. Gneiting" on Justia Law

A district court granted Michael Bonner's motion to suppress evidence following a traffic stop that lead to his arrest for driving without privileges and for DUI. Bonner argued that the arresting officer lacked a reasonable articulable suspicion that a crime had occurred or was about to occur, and had seized Bonner by taking his identification and ordering him to sit on the curb. The State argued that Bonner had waived his Fourth Amendment rights in his parole agreement, and therefore lacked standing to object to the seizure. Alternatively, the State argued the police officer had made consensual contact with Bonner, and if the instruction for Bonner to sit on the curb constituted a detention, it was a seizure supported by reasonable articulable suspicion of criminal activity. After review, the Idaho Supreme Court concluded the district court erred in ruling that the police officer did not have a reasonable suspicion to detain Bonner. "Accepting the findings of the district court as true, we nonetheless conclude that the totality of the circumstances supports the conclusion that the officer articulated a reasonable basis for suspecting that illegal conduct was taking place. Therefore, while we acknowledge that this is a very close question, we conclude that the district court erred in granting the motion to suppress. In light of this ruling, it is unnecessary to address the State’s alternative theory that the stop was consensual." View "Idaho v. Bonner" on Justia Law