Justia Criminal Law Opinion Summaries

In 2019, Officer Pallas was off duty and not in uniform when he noticed defendant-respondent Jonathan Bell at an Albertsons grocery store in Hailey, Idaho. Bell appeared to be unsteady on his feet, was having difficulty walking, and appeared confused. As Pallas watched Bell get into the driver’s seat of his vehicle and begin to drive, he called Officer Murphy, who was Pallas’ training officer and on duty, to report Bell as possibly driving under the influence. Murphy told Pallas to call dispatch, which he did. Pallas gave dispatch a description of the vehicle, the license plate number, and reported that the driver appeared to be intoxicated. The issue this case presented for the Idaho Supreme Court's review centered on the scope of its holding in Idaho v. Clarke, 446 P.3d 451 (2019). There, the Court held that an individual could not be arrested without a warrant for a misdemeanor that was completed outside the arresting officer’s presence. The State of Idaho argued that the “in the presence of the arresting officer” requirement under Clarke could be satisfied by the collective knowledge of more than one officer to establish probable cause. Thus, though the arresting officer here did not witness Bell’s driving pattern for the DUI, the State argued he had sufficient “collective knowledge” from others to carry out the arrest. The magistrate court agreed with this position below and denied Bell’s motion to suppress. However, Bell appealed to the district court, which reversed the magistrate court’s decision, concluding that the Idaho Constitution prohibited a police officer from making a warrantless arrest for a DUI committed outside the officer’s presence, even if the officer had probable cause for that offense through his collective knowledge from another officer. Finding no reversible error in that decision, the Supreme Court affirmed the district court’s decision. View "Idaho v. Bell" on Justia Law

Defendant-appellant Robert Miller appealed his conviction for felony driving under the influence (“DUI”) and the district court’s application of a sentencing enhancement based on a prior conviction for felony DUI within the previous fifteen years. On appeal, Miller argued: (1) the district court erred in dismissing the jury before it heard and determined the facts regarding the sentencing enhancement without first obtaining a valid waiver of Miller’s right to a jury trial; (2) the appropriate remedy for the error was to determine the sentencing enhancement did not apply; and (3) if the sentencing enhancement was still applicable to Miller, his sentence should be vacated and the case remanded for a new trial on whether Miller should be subject to the sentencing enhancement. Given the State’s concession that the district court committed fundamental error, the Idaho Supreme Court concluded the appropriate remedy was to vacate Miller’s sentence and remand for a new trial to determine whether the sentencing enhancement applied to Miller. View "Idaho v. Miller" on Justia Law

Defendant-appellant Mark Lankford appealed for the third time his 1983 convictions for the first-degree murders of Robert and Cheryl Bravence near Grangeville, Idaho. Errors in Lankford’s first two trials in 1984 and 2008 resulted in those convictions being vacated. Lankford was retried in 2019 and was again convicted of first-degree murder. Lankford appealed his third conviction, arguing: (1) the district court abused its discretion when it allowed the State to question Lankford’s brother about statements Lankford made on a late-disclosed prison phone recording; (2) the evidence was insufficient to support his conviction when the “law of the case doctrine” is applied to his case; and (3) the district court erred in denying Lankford’s motion to dismiss for a speedy trial violation. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Lankford" on Justia Law

Brandon Bahr appealed a district court’s summary dismissal of his untimely petition for post-conviction relief. Bahr filed his untimely petition roughly two years after the one-year statute of limitations had expired. The State responded with a motion seeking summary dismissal. Bahr opposed dismissal, arguing the limitations period should have been equitably tolled based on his alleged lack of access to the Idaho courts while transferred to, and incarcerated in, Texas prison facilities. The district court granted the State’s motion for summary dismissal. Bahr argued on appeal to the Idaho Supreme Court that the district court erred by denying him equitable tolling, and by declining to hold an evidentiary hearing concerning whether Bahr lacked access to the Idaho courts while incarcerated in Texas. The Supreme Court affirmed: "Even if Bahr was denied access to the Idaho courts while in Texas, a fact which we have not determined, he is not entitled to equitable tolling because he failed to allege any diligent efforts to pursue his rights while in Texas." View "Bahr v. Idaho" on Justia Law

Sean Anderson appealed his conviction and sentence for aggravated assault on a police officer. Anderson argued on appeal: (1) the district court erred by instructing the jury on a different theory of assault than what was alleged in the charging Information; (2) the district court erred by refusing to give his proposed jury instruction on the misdemeanor offense of discharge of a firearm aimed at another; and (3) the district court imposed an excessive sentence. The Idaho Supreme Court affirmed Anderson’s judgment of conviction, finding that the district court did not abuse its sentencing discretion. View "Idaho v. Anderson" on Justia Law

Defendant Stacy Ingraham appealed her convictions and sentences for possession of methamphetamine, possession of marijuana, possession of drug paraphernalia, destruction of evidence, and grand theft by possession of stolen property. She argued she was denied her right to a public trial under both the Idaho and U.S. constitutions, and that the district court erred by publishing a video exhibit to the jury after it began deliberations. Additionally, she contended the district court erred in allowing the jury to consider a prior felony conviction for purposes of a persistent violator enhancement where that conviction had previously been “deemed” a misdemeanor pursuant to Idaho Code section 19-2604. After review, the Idaho Supreme Court affirmed defendant's convictions, but vacated the sentence and remanded for resentencing. View "Idaho v. Ingraham" on Justia Law

When asked about recent negative behavior, defendant-appellant Jason Roberts’ fifteen-year-old son informed his mother that she would understand if she saw the signs that Roberts “was sexually hurting” him. A Children at Risk Evaluation Services (CARES) facility interview was ultimately arranged for the child. At the beginning of the interview, the interviewer informed the child that he would speak to a nurse after the interview. Upon hearing this, the child appeared taken aback. The interviewer clarified that “they’re just going to see how tall you are and how much you weigh.” The child responded, “Okay, I thought they were going to test me for [sexually transmitted infections]. I was like, ummm.” During the CARES interview, the child detailed how Roberts had sexually abused the child starting when he was seven or eight years old. The child related that the last episode of sexual abuse occurred about two and one-half years prior to the CARES interview. While discussing the instances of sexual abuse, the child stated that after the abuse, he struggled with “suicidal stuff” that resulted in the child being “locked up.” The child indicated that after his release, he again struggled with “suicidal stuff” because the abuse continued. He admitted during the interview that he was having “a couple” thoughts about suicide, described his preferred method of self-harm, and indicated that at the time of the interview, he felt like engaging in self-harm a “little bit.” After the CARES interview, Roberts was indicted by a grand jury for two counts of lewd conduct with a minor child under age sixteen. At trial, the district court admitted a recording of the CARES interview over Roberts’ objection. In doing so, the district court found that the child was capable of making statements for medical purposes and that “there is little reason to doubt [the child’s] motivation in making the disclosures.” Both the child and Roberts testified at trial. Ultimately, the jury found Roberts guilty of both counts. Roberts appealed. Finding no abuse of discretion in admitting the CARES interview, the Idaho Supreme Court affirmed Roberts' judgment of conviction. View "Idaho v. Roberts" on Justia Law

Jane Doe appealed a district court’s decision to uphold the magistrate court’s judgment that Doe committed a battery—placing Doe within the purview of the Juvenile Corrections Act. Doe argued the magistrate court erred by using and applying the self-defense law reflected in Idaho Criminal Jury Instructions 1517 and 1518, instead of Idaho Code section 19-202A, Idaho’s “stand your ground” statute. Doe contended the statute’s legal standards differed from Instructions 1517 and 1518, and that the statutory standards should have been applied to her self-defense claim. To this, the Idaho Supreme Court disagreed: the "stand your ground" statute codified aspects of Idaho self-defense law that existed for over 100 years at common law, without abrogating those aspects it left uncodified. Thus, the Supreme Court held the district court did not err in upholding the magistrate court’s use and application of the pattern instructions, which presumptively reflected the elements of self-defense at common law. View "Idaho v. Jane Doe (2021-38)" on Justia Law

Respondent Camille Pool pleaded guilty to misdemeanor DUI in 2020. In May 2020, approximately two months following the onset of the coronavirus pandemic, Pool was sentenced at a hearing conducted over Zoom which she attended remotely. The State recommended Pool be sentenced to supervised probation with suspended jail time. The magistrate court ultimately sentenced Pool to 180 days in jail with 177 days suspended, granted her a withheld judgment, and placed her on supervised probation for 18 months. The magistrate court went on to explain some of the terms Pool would need to accept in order to receive probation. The following day, the magistrate court entered a written Judgment of Conviction: a form document for DUI cases. A paragraph next to the probation check box listed possible probation terms, which included: "Defendant specifically waives his/her 4th Amendment right to warrantless search of his/her person, vehicle, or residence by any law enforcement or probation officer." The form included a line for the defendant’s signature, but Pool was not personally present in the courtroom and, therefore, did not sign the Judgment. Instead, on the signature line, someone handwrote “mailed to defendant 5/27/2020.” While on probation, Pool failed to appear for drug and alcohol testing and failed to comply with other terms of her probation. On April 14, 2021, three probation officers went to Pool’s residence to conduct a residence check. One officer spoke with Pool, mentioned the Fourth Amendment waiver, and Pool indicated that she understood. Pool’s residence was searched and drugs and drug paraphernalia were found. Pool was charged with felony possession of a controlled substance and a misdemeanor charge for possession of drug paraphernalia. Pool moved to suppress the items seized and the statements she made during the search of her home, arguing that, among other things, she had not waived her right against search and seizure under Article I, section 17 of Idaho’s Constitution and, therefore, the search violated her rights under the Idaho Constitution. The Idaho Supreme Court determined the search was lawful and reversed the district court's decision granting the motion to suppress. View "Idaho v. Pool" on Justia Law

Thomas Hooley appealed a district court’s summary dismissal of his petition for post-conviction relief. In 2014, Hooley was convicted of aiding and abetting aggravated battery and kidnapping in the first degree. Hooley petitioned for post-conviction relief in 2019, claiming: (1) he was actually innocent; and (2) the prosecution withheld favorable evidence. The district court concluded that Hooley’s actual innocence claim was time-barred and further concluded the claim failed on the merits. While the district court found that Hooley’s evidence claim was timely, the court ultimately determined the claim failed on the merits, and dismissed the petition without an evidentiary hearing. Finding no reversible error in the summary disposition, the Idaho Supreme Court affirmed the district court. View "Hooley v. Idaho" on Justia Law