Justia Criminal Law Opinion Summaries

Kody Gibbs appealed a district court’s order extending his probation. In 2013, Gibbs was charged with delivery of a controlled substance after he sold methamphetamine to a minor. Pursuant to plea negotiations, Gibbs pled guilty to delivery of a controlled substance, and the district court dismissed allegations that the delivery was to a minor and that Gibbs was a persistent violator. The district court imposed a suspended sentence of fifteen years, with ten years fixed, and placed Gibbs on probation for five years. One condition of Gibbs’ probation required him to successfully complete mental health court. In the subsequent years, Gibbs got in trouble by taking prohibited drugs, drinking, and committing felony sexual exploitation of a child. Gibbs would also be indicted by a federal grand jury for possessing child pornography. Gibbs argues on appeal of his state charges that: (1) he was denied his constitutional right to due process because his case was not heard by an impartial judge; and (2) the district court abused its discretion by increasing, sua sponte, his probation from a term of six years to life. Finding no abuse of discretion or reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Gibbs" on Justia Law

Gilberto Garza, Jr., appealed a district court’s dismissal of his petitions for post-conviction relief. Garza signed two plea agreements relating to charges of aggravated assault and possession of a controlled substance with intent to distribute. As part of his plea agreements Garza waived his right to appeal. Despite the waivers, Garza instructed his attorney to appeal. Garza’s attorney declined to file the appeals, citing the waivers of appeal in the plea agreements. Garza then filed two petitions for post-conviction relief on his own, alleging his counsel was ineffective for failing to appeal. The district court dismissed Garza’s petitions concluding Garza’s counsel was not ineffective in failing to appeal. The Court of Appeals and the Idaho Supreme Court agreed and affirmed. View "Garza v. Idaho" on Justia Law

Trevor Lee appealed a district court’s denial of his motion to suppress evidence. As part of his plea agreement, Lee reserved the right to challenge the denial of his suppression motion on appeal. The district court concluded the pat-down frisk was reasonable under Terry v. Ohio, 392 U.S. 1 (1968), but the officer exceeded the scope of the frisk by opening the containers found in Lee’s pocket. However, the district court concluded the search of the containers was permissible as a search incident to Lee’s arrest because, prior to the search, the officer had probable cause to arrest Lee for driving without privileges and the search was substantially contemporaneous with the arrest. The court of appeals agreed and affirmed the district court’s denial of Lee’s motion to suppress. The Idaho Supreme Court found after review: (1) the district court correctly concluded that the frisk was justified under Terry but that the arresting officer exceeded the scope of a permissible frisk when he opened the containers found on Lee; and (2) the district court therefore erred in concluding the search of Lee's person was a permissible search incident to arrest. The Court vacated the conviction, reversed the district court’s denial of Lee’s motion to suppress, and remanded for further proceedings. View "Idaho v. Lee" on Justia Law

Defendant-appellant Jonathan Folk was convicted by jury on one felony count of sexual abuse of a child under sixteen years old. On appeal, Folk contended the district court made numerous evidentiary errors. Folk also argued that the district court erred by denying his motion for a judgment of acquittal and the prosecutor committed misconduct amounting to fundamental error in his closing argument. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Folk" on Justia Law

Darol Anderson appealed his convictions for felony domestic battery and misdemeanor domestic battery, arguing the district court erred when it admitted the preliminary hearing testimony of his alleged victim, Erica Messerly, after finding that she was unavailable to testify at his trial due to mental illness. Anderson also argued the district court abused its discretion when it allowed a responding officer to testify that the injuries that he had observed on Messerly’s person were consistent with her allegations against Anderson. Anderson contended the officer’s testimony constituted impermissible vouching for Messerly’s truthfulness. The Idaho Supreme Court found the district court erred in admitting Messerly’s testimony from the preliminary hearing in this case because the State failed to establish Messerly was unavailable to testify. The Court affirmed the conviction in all other respects. View "Idaho v. Anderson" on Justia Law

Matthew Cohagan appealed the district court’s denial of his motion to suppress. Following the denial of his motion, Cohagan entered a conditional guilty plea to possession of methamphetamine. Cohagan argued on appeal that the evidence seized when he was arrested should have been suppressed because it was “the direct result of the illegal detention because Officer Curtis detained [him] so that he could run a warrant check.” The Idaho Supreme Court determined there was no reason for the arresting officers to initiate a traffic stop in the first instance, so the evidence seized thereafter was indeed, the result of an illegal detention. The Court therefore reversed the denial of the motion to suppress and remanded for further proceedings. View "Idaho v. Cohagan" on Justia Law

In 2013, while under the influence of a controlled substance, suffering from schizophrenia, and experiencing paranoia and a delusion that he and his family were in danger, defendant Shawn Fisher killed one person and attempted to kill another. He apparently selected his victims at random. Defendant was ultimately charged with murder in the first degree and several other crimes, but the district court found him unable to assist in his own defense due to his mental illness. Defendant filed a motion seeking to have the statutory abolition of the insanity defense declared to be unconstitutional; the district court denied the motion. The prosecutor, defense counsel, and defendant entered into a binding plea agreement, which provided that defendant would plead guilty to murder in the second degree, the remaining charges would be dismissed, and defendant would reserve the right to appeal the district court’s denial of his motion to declare unconstitutional the statutory abolition of the insanity defense. There was no agreement as to the sentence. The State later filed an amended information reducing the charge of murder in the first degree to murder in the second degree. On the same day, defendant pled guilty to murder in the second degree. The district court held a sentencing hearing sentenced defendant to a determinate life sentence with no possibility for parole. On appeal, Defendant contended that the abolition of the insanity defense violated the Due Process Clause of the Fourteenth Amendment and the Eighth Amendment. Finding no such constitutional violation nor an abuse of the district court’s discretion in sentencing defendant, the Idaho Supreme Court affirmed. View "Idaho v. Fisher" on Justia Law

Defendant-appellant Darol Anderson appealed his convictions for felony domestic battery and misdemeanor domestic battery. Anderson argued the district court erred when it admitted the preliminary hearing testimony of his alleged victim, Erica Messerly, after finding that she was unavailable to testify at his trial due to mental illness. Anderson also argued that the district court abused its discretion when it allowed Officer Spencer Mortensen to testify that the injuries that he had observed on Messerly’s person were consistent with her allegations against Anderson; he argued this testimony constituted impermissible vouching for Messerly’s truthfulness. Unavailability due to mental illness was an issue of first impression for the Idaho Supreme Court. The Court determined two experts’ testimony were not sufficient evidence to establish that Messerly’s mental illness made her unavailable to testify, so the district court erred when it granted the motion in limine to allow her prehearing testimony to be read at trial. The district court did not abuse its discretion, however, by admitting Officer Mortensen’s testimony. Therefore, the district court’s judgment was vacated in part and affirmed in part. View "Idaho v. Anderson" on Justia Law

The district court igranted a motion to suppress statements made by defendant-respondent Tyrell McNeely to Detective Zane Jensen after finding that the Miranda warnings given to McNeely did not adequately advise him of his rights. On appeal, the State argued the district court erred when it followed case law from the Ninth Circuit Court of Appeals requiring police to advise suspects of their right to have an attorney present during interrogation. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. McNeely" on Justia Law

Mark Henry Lankford (Lankford) appealed after he was convicted by jury on two counts of felony murder. Lankford and his brother, Bryan Lankford (Bryan), were both convicted and sentenced to death for the 1983 murders of Robert and Cheryl Bravence, who were brutally murdered while camping in the Sheep Creek area of Idaho County. Lankford argued that the district court erred in multiple ways and that he is entitled to a new trial. The State argued Lankford failed to prove that reversible error was committed by the district court and that Lankford’s convictions should be affirmed. After review, the Idaho Supreme Court found that a witness' false testimony about his motive for testifying could have influenced the judgment of the jury. Furthermore, the Court found that the prosecutor's failure to disclose the full details of the agreement for the witness to testify undermined "[its] confidence in the outcome of the trial such that we cannot be sure the defendant 'received a fair trial, understood as a trial resulting in a verdict worthy of confidence.'" Therefore, the Court held Lankford's right to a fair trial was violated and he was entitled to a new one. View "Idaho v. Lankford" on Justia Law