Justia Criminal Law Opinion Summaries

On July 12, 2014, around 5:00 A.M., Ben Savage appeared at the Custer County Sheriff’s Office and reported that defendant-respondent Jon Huffaker had pointed a loaded rifle and threatened to kill him. At approximately 6:00 A.M. Sergeant Shawn Kramer located Huffaker walking his dog in a nearby field. Sgt. Kramer did not activate his lights or siren and did not otherwise make contact with Huffaker. Huffaker noticed Sgt. Kramer’s vehicle and approached it. Sgt. Kramer then informed Huffaker of Savage’s allegations against him. At that time, Sgt. Kramer noticed that Huffaker appeared intoxicated. Sgt. Kramer offered to give Huffaker a ride to the Sheriff’s Office so he could give Deputy Levi Maydole his side of the story. Huffaker agreed, and Sgt. Kramer drove Huffaker and his dog to the Sheriff’s Office. During the ride to the Sheriff’s Office, Huffaker rode in the passenger seat of Sgt. Kramer’s law enforcement vehicle while his dog rode in the back seat. In the course of his interaction with Sgt. Kramer, Huffaker was not frisked or handcuffed. He was not physically or verbally coerced by Sgt. Kramer into entering the law enforcement vehicle. He was never told that he was being arrested, detained, or otherwise deprived of his freedom. After a roughly five minute interview, Deputy Maydole informed Huffaker that he was under arrest. Roughly three hours after having been arrested, Huffaker requested and was provided with a “Voluntary Statement” form, on which he wrote down an account of the events from that morning, which contained incriminating statements similar to those he had made during his interview with Deputy Maydole. Prior to trial, the district court suppressed both Huffaker’s interview and his written statement under Miranda. The district court reasoned that Huffaker was “in custody” during the interview because: (1) “Defendant has no way of returning home because he was intoxicated and Kramer had given him a ride to the station”; (2) “Defendant was questioned as the sole suspect by a law enforcement officer”; (3) “[h]e was not told he was free to leave”; and (4) “[a] normal person in Defendant’s circumstances would not have believed they could end the interview and freely leave the police station.” Following entry of the order granting Huffaker’s motion to suppress, the State appealed to the Court of Appeals. The Court of Appeals affirmed the order as to Huffaker’s written statement, but reversed as to his oral statements, concluding that he was not in custody when those statements were made. The Supreme Court vacated the district court's order suppressing both Huffaker's written and oral statements, finding that Huffaker was not in custody when his statements were made, and that the written statement was not drafted in response to interrogation. View "Idaho v. Huffaker" on Justia Law

Defendant-appellant Lance Taylor appealed a district court order denying him credit for time served as a condition of probation. Specifically, the credit he sought was for periods of incarceration during his drug court program. Taylor argued the district court erred: (1) for not giving retroactive effect to the Credit Statutes, Idaho Code 18-309 and 19-2603; and (2) misinterpreting the conditions of his probation, in the event that he was not entitled to credit for his incarceration during the drug court program. After review, the Idaho Supreme Court affirmed the district court's order insofar as it awarded credit for time served for certain periods of Taylor's drug court incarceration. However, the Court reversed the order insofar as it denied credit for certain other periods. The case was remanded for determination of the total number of days to be applied against Taylor's sentence. View "Idaho v. Taylor" on Justia Law

Defendant-appellant Daniel Leary appealed a district court’s order revoking probation and imposing his sentence. He argued the district court erred in calculating his credit for time served. He contended that the 2015 amendments to Idaho Code sections 18-309 and 19-2603 (the "Credit Statutes") should have been given retroactive effect, requiring the district court to give him credit for all time served on previous drug court bench warrants, which were a condition of his probation. The Supreme Court affirmed, finding "an express declaration of retroactive effect is absent from the plain language of the Credit Statutes. The Legislature clearly knows how to expressly declare retroactive effect when drafting a statute, and such a declaration is absent in the Credit Statutes." View "Idaho v. Leary" on Justia Law

Appellant Dale Shackelford was sentenced to death after being convicted of two counts of first-degree murder and other crimes. He appealed and sought post-conviction relief, and his death sentence was set aside. At resentencing, Shackelford was sentenced to two consecutive fixed life sentences. Shackelford petitioned for post-conviction relief based on the resentencing proceeding. He also petitioned again for post-conviction relief based on the original criminal trial. The district court summarily dismissed both petitions and Shackelford appealed each. The appeals were consolidated in this case, and presented the following issues for the Supreme Court's review: (1) whether the district court erred in summarily dismissing Shackelford's amended successive petition; (2) whether the district court erred in summarily dismissing Shakelford's resentencing petition; and (3) whether the district court erred in denying Shackelford's motion for appointment of counsel related to the amended successive petition. Finding no reversible error as to any of Shackelford's issues raised on appeal, the Supreme Court affirmed. View "Shackelford v. Idaho" on Justia Law

Appellant Troy Svelmoe was convicted by jury of felony driving under the influence (DUI). Svelmoe was pulled over in Post Falls for vehicle equipment violations. The officer suspected that Svelmoe was driving under the influence and asked Svelmoe to perform three field sobriety tests. Svelmoe failed two of the tests and was placed under arrest. At the preliminary hearing, the State did not present the results of the breath tests, and the magistrate judge dismissed the complaint for lack of probable cause to support the charge. The prosecution then refiled the criminal complaint and introduced the results of the breath tests at a second preliminary hearing. The judge concluded that the prosecution presented substantial evidence to support the charge. At the district court, Svelmoe filed a motion to dismiss the DUI charge, a motion to suppress the breath test results, and a motion in limine to exclude the breath test results. The district court denied all three of Svelmoe’s motions, and the matter proceeded to trial. Svelmoe appealed, challenging the district court’s denial of his pretrial motions. Finding that the district court erred in denying Svelmoe's motion in limine and in admitting the breath test result, the Idaho Supreme Court vacated the conviction and remanded this case for further proceedings. View "Idaho v. Svelmoe" on Justia Law

In 2013, defendant Dakota Lee Villafuerte was placed on probation for the felony crime of battery with the intent to commit lewd and lascivious conduct with a child under sixteen years of age. The conviction for that crime required that he register as a sex offender. Before being released on probation, he completed a sex offender registration form listing his intended address as his parents’ residence. As a condition of his probation, Defendant was ordered to serve seven days of discretionary jail time. He was released from jail on November 13, 2013. On November 27, the State filed a complaint charging Defendant with the crime of failing to update his sex offender registration. The supporting affidavit stated that Defendant’s probation officer stopped at the home of Defendant’s parents on November 18, 2013; that they stated that they had not seen Defendant for just over one and one-half weeks; that since Defendant was released from jail his location was unknown; and that Defendant had not updated his current address in his sex offender registration. Based upon the affidavit, the court issued a warrant for Defendant’s arrest. On May 26, 2014, Defendant was arrested in Utah. Defendant moved to dismiss on the ground that the State lacked jurisdiction over the crime charged. The district court denied the motion to dismiss. Defendant entered into a written plea agreement pursuant to which he would plead guilty to the charge, reserve the right to appeal the denial of his motion to dismiss, and have the right to withdraw his guilty plea if he prevails on appeal. The district court sentenced him to six years in the custody of the Idaho Board of Correction to run consecutively to the sentence for which he had been on probation. His probation was apparently revoked, and he was required to serve his suspended sentence. The issue on appeal was whether the district court erred in finding jurisdiction over the charge. Based on its review of the district court record, the Supreme Court found no reversible error and affirmed. View "Idaho v. Villafuerte" on Justia Law

An information was filed charging Gerald Umphenour with possession of methamphetamine, a felony, and with resisting and obstructing an officer and having an open container of alcohol in a motor vehicle, both misdemeanors. On appeal, he contended that the district court failed to secure an express waiver from the defendant of his right to a jury trial before proceeding with a court trial. The appeal was initially heard by the Idaho Court of Appeals, which vacated Umphenour’s conviction on the ground that the district court had conducted a court trial without first obtaining Umphenour’s personal, express waiver of his right to a jury trial. The Supreme Court granted the State’s petition for review. "Because the aberrant procedure used by the district court was, in essence, a guilty plea and not a court trial," the Supreme Court affirmed the district court. View "Idaho v. Umphenour" on Justia Law

Respondent Kyle Rios was involved in a car accident in Lewiston. After the accident, Rios was arrested and taken to a nearby hospital by Officer Williams. At the hospital, Rios declined to sign a consent form for a blood draw. Without obtaining a warrant, Officer Williams directed hospital staff to draw Rios’ blood for a blood alcohol test. Rios did not verbally or physically resist. Based in part on the results of the blood alcohol test, Rios was charged with felony vehicular manslaughter and felony leaving the scene of the accident. Rios filed a motion to suppress the results of the blood alcohol test, alleging the results were obtained through an unlawful search and seizure. The district court granted Rios’ motion, concluding Rios withdrew implied consent to the blood draw by declining to sign the consent form. The State appealed. The Supreme Court reversed, finding that the State seemed to argue Rios renewed his consent by voluntarily presenting his arm to the phlebotomist and failing to verbally or physically resisting the blood draw. "These actions show only that Rios complied with the officer’s orders. Compliance with an officer’s orders alone does not renew consent." The Court held that Rios revoked implied consent by declining to sign the consent form, and therefore upheld the district court’s order suppressing the results of the blood alcohol test. View "Idaho v. Rios" on Justia Law

Defendant Brian Pratt was charged with two counts of delivery of a controlled substance and one count of trafficking in methamphetamine, all of which were felonies. He absconded after the first day of trial and was found guilty of all three counts in absentia. He was arrested about three months later. For each of the charges of delivery of a controlled substance (counts one and three), the district court sentenced him to the custody of the Idaho Board of Correction for five years, with two years fixed and the remaining three years indeterminate, and the court ordered that those sentences run concurrently. For the trafficking charge (count two), the court sentenced him to the custody of the board of correction for a period of twenty years, with the first ten years fixed and the remaining ten years indeterminate. The court ordered that this sentence be served consecutively to the sentences for counts one and three. Defendant appealed, challenging only the district court’s denial of his motion for a mistrial based upon a comment made by a prospective juror during voir dire. Finding that defendant passed the jury for cause at the end of the voir dire examination, he waived any objection to the jury panel. Therefore, the Supreme Court affirmed the judgment of the district court. View "Idaho v. Pratt" on Justia Law

Petitioner-appellant Shane Crawford petitioned for post-conviction relief after he was convicted for lewd conduct with a minor under the age of sixteen. Petitioner claimed he received ineffective assistance of counsel at both the trial and appellate stages. At the trial stage, Crawford claimed that his counsel was deficient in failing to request that the court either instruct the jury that manual-genital contact requires touching the vaginal area or define the term “genital.” Furthermore, he asserted that his trial counsel erred by failing to move for acquittal based upon insufficient evidence. On direct appeal of the conviction, Crawford’s counsel similarly did not raise a sufficiency of the evidence claim, which Crawford claimed constituted ineffective assistance of appellate counsel. The district court summarily dismissed Crawford’s petition, and he appealed. The Court of Appeals affirmed the summary dismissal. Crawford now seeks relief from this Court to have the summary dismissal of his claim reversed. Finding no reversible error in the summary dismissal of his claims, the Supreme Court affirmed. View "Crawford v. Idaho" on Justia Law