Justia Criminal Law Opinion Summaries

Edgar Farfan-Galvan appealed his conviction for felony driving under the influence (“DUI”). Farfan-Galvan moved to dismiss or remand the charge, based upon his claim that one of the prior DUI convictions upon which the State relied to enhance the charge from a misdemeanor to a felony was obtained in violation of his Sixth Amendment right to counsel. The district court denied the motion. The Supreme Court reversed. The record before the district court did not contain any indication that Farfan-Galvan had waived the right to counsel in the prior 2010 case. Therefore, that conviction could not serve as the basis to enhance the charge to a felony. The district court’s decision denying his motion to dismiss or remand. was reversed, and in light of this, the Court vacated Farfan-Galvan’s conviction. View "Idaho v. Farfan-Galvan" on Justia Law

Alik Takhsilov appealed the district court’s summary dismissal of his petition for post-conviction relief, arguing that his trial counsel was ineffective for failing to request a competency evaluation prior to his entry of guilty pleas. During the pendency of his underlying criminal case, Takhsilov was deemed incompetent to proceed and was transferred to Idaho State Hospital South pursuant to Idaho Code section 18-212. Three months later, he was found to have regained competency, and he was returned to the district court. Takhsilov then entered guilty pleas to one count of robbery under Idaho Code section 18-6501 and one count of burglary under Idaho Code section 18-1404. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Takhsilov v. Idaho" on Justia Law

Jonathan Hill was convicted for felony driving under the influence (DUI). He raised one issue on appeal. Over an unsuccessful hearsay objection, the deputy sheriff who conducted field sobriety tests (FSTs) of Hill was permitted to testify as to what he had been taught regarding the presence of vertical nystagmus. Hill’s appeal challenged that evidentiary ruling. The Supreme Court found that even if the testimony was relied upon for the basis of an expert opinion, it was improper to disclose the facts upon which Deputy Smith based his opinion. This error was not harmless, and as such, the Supreme Court vacated Hill's conviction and remanded the matter for a new trial. View "Idaho v. Hill" on Justia Law

Defendant-appellant John Linze, Jr. appealed after he was convicted for conviction of possession of methamphetamine. On appeal, he argued the district court erred by refusing to suppress evidence obtained by police during a traffic stop. Specifically, Linze argued that: (1) the traffic stop was impermissibly extended in order to allow time for the drug detection dog to arrive; (2) the traffic stop was impermissibly extended in order to allow the drug detection dog to conduct a sweep; and (3) the alert of the drug detection dog was insufficient to establish probable cause to search the vehicle because the dog was unreliable. Linze’s initial appeal before the Court of Appeals resulted in his conviction being vacated. That court held that the time during which the drug detection dog conducted its sweep of the vehicle was an impermissible extension of the original traffic stop. The Supreme Court agreed with that reasoning and affirmed the appellate court. The district court’s judgment was vacated (as was the order of probation), and the order denying Linze’s motion to suppress was reversed. View "Idaho v. Linze" on Justia Law

Cesar Sepulveda appealed after a jury found him guilty of felony intimidating a witness, misdemeanor domestic battery, injury to a child, and two counts of attempted violation of a no contact order. Sepulveda contended that his right to confront witnesses, his right to present a defense, and his right to be free from double jeopardy were violated and that his convictions should have been vacated. Finding no such violations, the Supreme Court affirmed Sepulveda's convictions. View "Idaho v. Sepulveda" on Justia Law

Scott Ostler was convicted of three counts of lewd conduct with a minor child under sixteen, and one count of sexual abuse of a child under the age of sixteen. This appeal related only to a single count of lewd conduct: Ostler claimed that the State violated his right to due process by adding an additional lewd conduct charge following a mistrial. The Court of Appeals vacated Ostler’s conviction for the additional felony, agreeing that the State violated Ostler’s right to due process. The Supreme Court affirmed the district court's judgment of conviction: "The proper avenue for Ostler to seek relief is in post-conviction proceedings." The Court ruled that Ostler “may still file a petition for post-conviction relief proceedings in order to ascertain whether defense counsel’s failure to object to the alleged error constituted ineffective assistance of counsel.” Ostler’s claim of prosecutorial vindictiveness required further factual development as to why the State added an additional lewd conduct charge. View "Idaho v. Ostler" on Justia Law

Appellant Miguel Cosio-Nava pled guilty in 2014 to the felony offense of domestic battery with traumatic injury, in violation of Idaho Code sections 18-903 and 18-918(2). Cosio was a Mexican citizen who had been in the United States since 1992 as a Legal Permanent Resident (“LPR”). At his sentencing hearing, the court discussed immigration issues with Cosio and his trial counsel. Cosio appealed the district court’s dismissal of his petition for post-conviction relief, in which he alleged that trial counsel provided him ineffective assistance by failing to advise him of the immigration consequences of pleading guilty. After review of the district court record, the Supreme Court found no error in the dismissal of Cosio's petition for relief and affirmed. View "Cosio-Nava v. Idaho" on Justia Law

Marcelino Baeza appealed his conviction for one count of lewd conduct with a minor child under the age of sixteen involving his five-year-old niece, J.C. Baeza argued that allowing J.C. to testify at trial through closed-circuit television violated his due process right to a fair trial and presumption of innocence and that the district court failed to adequately consider the relative rights of the parties under Idaho Code section 9-1806 when it ordered the alternative method for presenting J.C.’s testimony. Finding no due process violation, the Supreme Court affirmed the conviction. View "Idaho v. Baeza" on Justia Law

In 2010, Kandi Hall (“Kandi”) was looking for work, having been fired from her previous job as a paralegal. Emmett Corrigan (“Emmett”) was waiting to learn the results of the bar exam he had taken and wanted to hire a paralegal to work for him when he began practicing law. They were introduced by a mutual friend. Kandi and Emmett were immediately attracted to each other, and within two weeks they began having a sexual relationship. Emmett passed the bar exam, and he hired Kandi in November to work for him in the law office he had opened. Their relationship continued until March 11, 2012, when Kandi’s husband, Robert Dean Hall (“Rob”), shot and killed Emmett in the parking lot of a pharmacy. A jury found Rob guilty of murder in the second degree. Kandi testified at trial that she always loved her husband, never intended to leave him, and was committed to their marriage. She was the only witness to the events leading up to Emmett's shooting. The issue in this appeal of Rob's conviction on second-degree murder charges was whether the district court properly instructed the jury on the issue of self-defense (Rob himself had been shot in the confrontation with Emmett). After review of the district court record, the Idaho Supreme Court held that the district court did not err in its instruction and affirmed the judgment of conviction. View "Idaho v. Hall" on Justia Law

Defendant-appellant Kirk Charlson appealed after he was convicted for felony driving under the influence. Before the trial, Charlson filed a motion to suppress the results of an evidentiary blood draw that was conducted without a warrant. The district court denied the motion, and Charlson was convicted. On appeal of the denial of his motion to suppress the results of the evidentiary blood draw, Charlson argued the draw violated his Fourth Amendment rights. When the totality of the circumstances in this case were considered, the Supreme Court concluded the State established voluntary consent to evidentiary testing sufficient to obviate the need for a warrant to draw Charlson’s blood. Although the district court did not have the benefit of the Supreme Court’s recent relevant opinions, it nonetheless reached the correct result. Therefore, its order denying Charlson’s motion to suppress the evidence against him was affirmed. View "Idaho v. Charlson" on Justia Law