Justia Criminal Law Opinion Summaries

Petitioner Erick Hall was convicted and sentenced to death twice: first for kidnapping, murder and rape; second for rape and murder. While Hall's petition for post-conviction relief was pending for his first sentence, his second trial for rape and murder was underway. During the overlap of Hall I and Hall II, there were numerous communications between Hall's trial attorneys representing him in Hall II, and the State Appellate Public Defender's (SAPD) office, handling Hall's post-conviction proceedings in Hall I. It was the communications between Hall's trial counsel that were the basis for a potential conflict of interest in this case, given that the issue before the Supreme Court in this appeal was ineffective assistance of trial counsel in his second petition for post-conviction relief. In 2008, Hall filed a petition for post-conviction relief in connection with his Hall II conviction. Two years later, the SAPD filed an Ex Parte Notice of Possible Conflict of Interest with the district court. The Ex Parte Notice stated that the SAPD had "cooperated with trial counsel in Hall II by sharing testing and expert information obtained in Hall I." Dennis Benjamin [. . .] agreed to evaluate the conflict and advise Mr. Hall whether or not the conflict should be waived." With no knowledge of the Ex Parte Notice, the State filed a Motion for Inquiry into Possible SAPD Conflict. Although Benjamin conducted an extensive inquiry into whether the SAPD was conflicted, the district court did not question Benjamin about his findings. Rather, the court believed that Benjamin was too closely aligned with the SAPD to be truly independent. The court then issued a Memorandum Decision and Order Appointing Keith Roark as Independent Counsel. The SAPD filed a Motion to Reconsider Memorandum Decision, which the court denied. On appeal, Hall acknowledged the trial court had an affirmative duty to inquire into a potential conflict whenever it knew or reasonably should have known that a particular conflict may exist. However, Hall argued that the cases relied on by the district court in finding that it had an affirmative duty to conduct a thorough and searching inquiry were distinguishable because the possibility of a conflict in this case was raised by Hall's counsel, not Hall himself. Additionally, Hall contended that Roark's conflict inquiry was unnecessary and duplicative because: (1) Benjamin assessed the possible conflict and concluded no conflict existed; and, (2) Benjamin made his conclusion after reviewing all relevant information. Further, Hall argued that the district court's second inquiry was unnecessary because the conduct of Hall's previous attorneys at the SAPD's office should not have been imputed to Hall's then-current post-conviction counsel. After its review, the Supreme Court concluded the district court erred in appointing Roark as independent counsel; the district court order granting Roark access to the SAPD's client file violated Hall's attorney-client privilege. Therefore the Supreme Court vacated the district court's order appointing Roark as independent conflict counsel and its order requiring the SAPD to pay for Roark's services. View "Hall v. Idaho" on Justia Law

In 1991, appellant Zane Fields was sentenced to death for first degree murder. In 2011, appellant filed his sixth successive petition for post-conviction relief. He raised claims of actual innocence, prosecutorial misconduct, and violations of the right to counsel, due process, and the right to a fair trial. The district court granted the State's motion to dismiss appellant's petition because his claims were barred by I.C. 19-2719(5). Appellant appealed the district court's dismissal of his petition. Finding no reversible error, the Supreme Court affirmed. View "Fields v. Idaho" on Justia Law

The issue on appeal before the Supreme Court in this case arose from an order denying an employer's motion to have a laptop returned that had been seized from its employee during a search conducted at the employee's home by a probation officer. The Court affirmed the order denying the return of the laptop, but held that the laptop could not be searched without a search warrant issued upon a judicial finding of probable cause. View "Idaho v. Ruck" on Justia Law

The issue on appeal before the Supreme Court arose from a district court order that denied Defendant's motion to dismiss for the lack of probable cause, a felony charge of possession of methadone. The methadone was discovered upon the birth of the defendant's baby girl in the umbilical cord. Upon review of the matter, the Supreme Court held that for the purposes of determining whether there was probable cause to believe that the defendant had possessed a controlled substance, the magistrate judge could reasonably have inferred that the defendant consumed the methadone; that she possessed it before she consumed it; and that she knew it was either methadone or a controlled substance when she was possessing it. View "Idaho v. Neal" on Justia Law

Defendant Todd Carver was convicted of murdering the three-year-old son of his live-in girlfriend. He appealed, arguing that the district court erred in failing to appoint substitute counsel for him, in its instructions to the jury defining the crime, and in calculating his sentence. Finding no reversible error, the Supreme Court affirmed defendant's conviction and sentence. View "Idaho v. Carver" on Justia Law

Defendant-Appellant Jose Brunet appealed a district court's order relinquishing jurisdiction and denying his oral motion requesting leniency pursuant to Rule 35 of the Idaho Criminal Rules. Appellant also argued that the Supreme Court's order denying his motion to augment the appellate record violated his constitutional rights to due process and equal protection, and would deny him effective assistance of counsel on appeal. Upon review of the matter, the Supreme Court affirmed the district court's order and held that appellant failed to show that the denial of his motion to augment the appellate record with additional transcripts violated his constitutional rights. View "Idaho v. Brunet" on Justia Law

Defendant-Appellant Joseph Clinton was indicted for felony lewd conduct with a minor under sixteen. Initially he was found incompetent to stand trial, but after reassessment, he was deemed competent. Thereafter he pled guilty, and underwent further assessment prior to receiving sentence. The sentencing court ultimately sentenced defendant to twenty years' incarceration, three years fixed and the remainder indeterminate. Defendant moved for reduction of the sentence, which was denied. The Court of Appeals affirmed defendant's sentence. The issues on appeal to the Supreme Court were: (1) whether the trial court erred in failing to order a mental evaluation sua sponte; and (2) whether the sentencing court abused its discretion in imposing defendant's ultimate sentence. Finding no errors, the Supreme Court affirmed. View "Idaho v. Clinton" on Justia Law

Defendant-Appellant Timothy Dunlap received the death penalty following his guilty plea to first-degree murder. He appealed the sentence, alleging multiple errors during trial, and that he received ineffective assistance of counsel. Although the Supreme Court found found error in the direct appeal from the sentencing proceedings, it held those errors, individually and cumulatively, were harmless. As to the appeal of the order summarily dismissing defendant's petition for post-conviction relief, the Court held that the district court erred in summarily dismissing defendant's claim of ineffective assistance of counsel regarding the investigation and presentation of mitigating evidence and the rebuttal of the State’s evidence in aggravation and defendant's "Brady/Napue" claim. Therefore, the Court vacated the district court’s judgment granting summary dismissal of defendant's petition for post-conviction relief and remanded the case for further proceedings. View "Idaho v. Dunlap" on Justia Law

Dale Shackelford appealed two consecutive fixed life sentences he received on resentencing for two first-degree murder convictions. He was initially sentenced to death for both murders but the death sentences were subsequently set aside. Shackelford contends that the district court committed error in resentencing him to the consecutive fixed life sentences. Upon review of the district court record, the Supreme Court concluded that the district court did not abuse its discretion nor violate Shackelford's Sixth Amendment right of confrontation. Accordingly, the Court affirmed the judgment of conviction sentencing Shackelford to two consecutive fixed life sentences. View "Idaho v. Shackelford" on Justia Law

Tyler Ray Carter pleaded guilty to aggravated battery on a correctional officer and was sentenced to fifteen years with five years fixed. He appealed the sentence arguing the district court failed to order a separate psychological evaluation prior to sentencing, and also violated his Fifth Amendment privilege against self-incrimination by using pre-trial competency evaluations in making its sentencing determination. Carter did not object to either the use of the competency evaluations or the court?s failure to order a psychological evaluation at trial. The Court of Appeals applied the "manifest disregard" standard to review Carter's claim that the court erred by failing to order a new psychological evaluation, and vacated the sentence. The Supreme Court granted the State's petition for review. The State argued that the fundamental error standard applied to all of Carter's unobjected-to evaulations. Upon review, the Supreme Court disagreed with the State's argument and affirmed the district court's judgment of conviction and sentence. View "Idaho v. Carter" on Justia Law