Justia Criminal Law Opinion Summaries

This case addressed whether a defendant accused of DUI could present expert testimony regarding his alcohol concentration at the time he was driving. In April 2015, a Sheriff’s Deputy pulled Justin Austin over for failure to use a turn signal. During the stop, the deputy detected the smell of alcohol, and Austin’s appearance further led the deputy to believe he was driving under the influence. After performing a field sobriety test, he arrested Austin and approximately thirty minutes after the initial stop conducted two breath tests that demonstrated alcohol concentrations above Idaho’s legal limit. Austin claimed that his consumption of three drinks in a short period of time just before the stop contributed to a rising alcohol concentration as he waited for the breath tests, and sought to introduce expert testimony to that effect. The district court granted the State’s motion in limine to exclude expert testimony as to his actual alcohol concentration as irrelevant under the DUI statute’s “per se” provision as interpreted by Idaho precedent. On appeal, Austin challenged the decision to grant the State’s motion, and alternatively challenged the DUI statute as overbroad or void for vagueness where there was no time limit within which approved alcohol concentration testing must be done to be used as evidence of a crime. The district court applied binding case law to grant the motion in limine. The Idaho Supreme Court clarified the law and felt compelled to hold that the district court’s decision to grant the State’s motion in limine constituted an abuse of discretion because it was not consistent with the legal standard now clarified. Accordingly, the Court vacated Austin’s conviction. View "Idaho v. Austin" on Justia Law

Gracie Tryon appealed her conviction for possession of a controlled substance. Tryon argued the district court erred when it admitted certain statements regarding the identity of the alleged controlled substance. Tryon claimed the admission of these statements violated her constitutional right to confront witnesses against her because the declarant was unavailable and she did not have a prior opportunity to cross-examine him. Tryon also asserted that the State did not present sufficient evidence to support a conviction for possession of a controlled substance. After review of the trial court record, the Idaho Supreme Court concluded the evidence in the record did not establish beyond a reasonable doubt that Tryon was in possession of a controlled substance. Tryon's sentence was vacated and the case remanded for the trial court to enter judgment of acquittal. View "Idaho v. Tryon" on Justia Law

The State of Idaho appealed a district court decision suppressing evidence found during a search of Brody Jaskowski’s pickup. Relying on Idaho v. Turek, 250 P.3d 796 (Ct. App. 2011), the district court held that Jaskowski’s probation agreement required that his probation officer request that Jaskowski submit to a search. The district court found that the probation officer did not make such a request of Jaskowski before searching his vehicle. Therefore, the district court suppressed evidence discovered in the course of the search. Finding no reversible error in that district court decision, the Idaho Supreme Court affirmed it. View "Idaho v. Jaskowski" on Justia Law

On February 14, 2016, after drinking, Roy Baxter “backhanded [his] wife in the throat area” while the two were driving in his car. When they stopped driving and got out of his car, they continued arguing, and Baxter “threatened to kill her and punched her in the arm.” Baxter’s abuse left his wife with “a traumatic injury” and bruising. A no-contact order prohibiting Baxter from attempting to “contact, harass, follow, communicate with, or knowingly remain within 100 feet of: [his wife]” was issued shortly thereafter, but Baxter “call[ed] and talk[ed]” to his wife “between 1-14 times” after the issuance of the no-contact order. In March, the State charged Baxter with domestic violence under Idaho Code section 18-918(2) and violating the no-contact order under Idaho Code section 18-920. The State proposed a plea agreement, whereby, in exchange for Baxter’s plea of guilty on the domestic violence charge, the State agreed to dismiss several other charges and recommend probation on the condition that a domestic violence evaluation rated Baxter’s likelihood to reoffend at “less than high risk[.]” As an additional contingency, the plea agreement prohibited Baxter from “acquiring a new criminal charge or charges between the date of this offer and sentencing, even if the charge or charges are not yet conviction(s).” Baxter was initially uncertain about whether to accept the State’s proposed plea agreement, and underwent a domestic violence evaluation. When the State reviewed the domestic violence evaluation, it grew concerned over “gross omissions” it felt Baxter had made concerning his drug use and violent conduct during the initial plea negotiations, and changed its terms for the agreement. Baxter entered a guilty plea. Baxter’s presentence investigation report (PSI) took into consideration Baxter’s evaluation, and recommended Baxter be placed on a rider. Baxter moved to withdraw his guilty plea, arguing the State’s “intervention with [with the physician evaluator] after [Baxter] entered his guilty plea rendered the plea agreement in this case meaningless.” Baxter did not claim innocence. The district court denied the motion, concluding Baxter had not met his burden to show the existence of a “just reason” to withdraw his plea. The Court of Appeals affirmed, and the Idaho Supreme Court also affirmed, finding Baxter did not show the existence of a just reason to withdraw his guilty plea. View "Idaho v. Baxter" on Justia Law

Torey Adamcik appealed his conviction and sentence for the murder of Cassie Stoddart when he was sixteen years old. The Idaho Supreme Court previously affirmed the conviction and sentence of life without the possibility of parole. Adamcik sought post-conviction relief on several claims, including ineffective assistance of counsel and that his sentence violated the federal and state bars against cruel and unusual punishment. The district court denied all of Adamcik’s claims following an evidentiary hearing. On appeal, Adamcik contended that the district court erred in denying his requested relief as to three of the ineffective assistance of counsel claims. Furthermore, he argued the district court erred in denying his claim that the imposed sentence of life without the possibility of parole violated the Eighth Amendment to the United States Constitution and Article 1, section 6 of the Idaho Constitution in light of recent Unites States Supreme Court opinions. Finding no reversible error, the Idaho Supreme Court affirmed the district court on denial of post-conviction relief. View "Adamcik v. Idaho" on Justia Law

The probation officers temporarily detained the visitors while conducting an initial search of the home to secure the remaining occupant. During this initial search, the searching officer observed drug paraphernalia in the garage, and the probation officers further detained the visitors until an investigative officer arrived. The investigative officer performed a pat-search on defendant-appellant Jason Downing, one of the visitors, which led to the discovery of drugs on his person. The officer further questioned him, which led to admissions of drug use that day. Downing sought to suppress all evidence obtained against him that day as derived from both an unlawful seizure and search. The district court denied his motion to suppress the drugs and admissions to the investigative officer. Finding that the district court erred in concluding that the investigative officer’s pat-down of defendant was reasonable under the totality of the circumstances, and that defendant’s post-Miranda statements to the officer were not sufficiently attenuated from that pat-down, the Idaho Supreme Court concluded the evidence derived from the search of the residence should have been suppressed. It vacated the judgment of conviction. View "Idaho v. Downing" on Justia Law

Daniel Montgomery appealed his conviction for unlawful discharge of a firearm at an occupied vehicle. Montgomery argued the district court abused its discretion when it allowed the State to present the testimony of two undisclosed rebuttal witnesses in violation of the requirements of Idaho Criminal Rule 16(b)(6). Montgomery also alleged that the prosecution engaged in misconduct by arguing during closing that certain witnesses lied, resulting in a violation of Montgomery’s right to a fair trial. Finding no reversible error, the Idaho Supreme Court affirmed the judgment of conviction. View "Idaho v. Montgomery" on Justia Law

The State appealed a district court’s order granting John Joseph Marr’s petition for post-conviction relief based on ineffective assistance of counsel at trial. Marr was arrested and charged with felony attempted strangulation and domestic battery with a traumatic injury. A jury found Marr not guilty as to the attempted strangulation but guilty of domestic battery with a traumatic injury. Marr’s direct appeal was unsuccessful and he filed a petition for post-conviction relief based on ineffective assistance of counsel at both trial and at sentencing. After a post-conviction evidentiary hearing, the district court found Marr’s attorney was ineffective at trial for failing to discover and admit evidence of the victim’s reputation for belligerence and aggression when intoxicated and for failing to elicit testimony from the victim about whether she had consumed alcohol before testifying. The district court granted Marr’s petition for relief as to trial, vacating Marr’s conviction. The district court denied Marr’s petition for post-conviction relief as to sentencing. The Court of Appeals reversed the district court’s grant of post-conviction relief. The Idaho Supreme Court granted Marr’s petition for review, and affirmed the district court’s order granting Marr’s petition for post-conviction relief. View "Marr v. Idaho" on Justia Law

In a consolidated appeal from Ada and Blaine County district court, the issue before the Idaho Supreme Court centered on credit for time served under Idaho Code section 18-309. Marco Antonio Rios-Lopez and Corey Dale Young (collectively, Appellants) sought credit for time served under the construction of section 18- 309, pronounced in Idaho v. Owens, 343 P.3d 30 (2015). The district courts denied Appellants’ motions, and the Court of Appeals affirmed. The district courts in both cases held that Appellants were not entitled to relief under Owens because their judgments of conviction had become final before Appellants filed their Rule 35 motions. Appellants do not contend they were sentenced incorrectly under Idaho v. Hoch, 630 P.2d 143 (1981). Rather, they sought relief under Owens, where, nearly 34 years after Hoch, the Idaho Supreme Court pronounced a different construction of section 18-309 and overruled Hoch. The Supreme Court expressed the construction of section 18-309 pronounced in Owens would apply “only prospectively and to cases now on [i.e., as of February 9, 2015] direct review.” Since Appellants’ judgments of conviction were final before Owens was decided, Appellants were not entitled to relief under Owens. View "Idaho v. Young" on Justia Law

In 2012, Teresa Tollman pled guilty to felony DUI. She was sentenced o a unified term of ten years, with two and a half years fixed followed by seven and a half years indeterminate. The judgment required Tollman's driver's license be absolutely suspended for five years beginning on the date of her release from custody. In 2016, Tollman applied or a restricted driver's license to drive to and from work. She appealed when the district court’s denied her motion for the restricted license. Specifically, Tollman argued the district court erred when it failed to apply a 2015 amendment to Idaho Code section 18-8005(6)(d) which permitted her to apply for a restricted driver’s license. Tollman argued that the Amendment should have been applied because she filed her request for a restricted driver’s license after the Amendment was enacted. The Idaho Supreme Court held that the district court properly determined that it did not have discretion to grant Tollman a restricted driver’s license. At the time Tollman received her sentence, Idaho Code section 18-8005(6)(d) provided that a court may suspend driving privileges for a period not to exceed five years after release from imprisonment, “during which time he shall have absolutely no driving privileges of any kind.” Complying with the law at the time, the district court judgment required Tollman’s driver’s license be absolutely suspended for five years beginning on the date of Tollman’s release from custody. Because Tollman’s sentence was final at the time the Amendment was enacted, and there was no legislative intent that the Amendment apply retroactively, the district court properly denied Tollman’s request for restricted driving privileges. View "Idaho v. Tollman" on Justia Law