Justia Criminal Law Opinion Summaries

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

Defendant Preston Joy was charged with felony domestic battery, sexual penetration by a foreign object, and second-degree kidnapping in connection with an altercation with his wife. A jury convicted defendant of domestic battery, acquitted on the sexual penetration charge, and was unable to reach a verdict on the kidnapping charge. He then entered a conditional guilty plea reserving his right to appeal all of the district court’s pre-trial, trial, and post-trial rulings. Defendant argued on appeal that evidence of prior misconduct was erroneously admitted, that the district court made other errors in admitting evidence, and that the district court erred by refusing to instruct the jury on lesser included offenses. Upon review, the Supreme Court vacated the conviction and remanded the case for a new trial. View "Idaho v. Joy" on Justia Law

In 2006, during the pendency of divorce proceedings, Charles Earl Guess, his wife, and their respective attorneys agreed that Ms. Guess and her attorney would meet Mr. Guess at the parties’ residence so that they could walk through the house and look in a vault in the house with Mr. Guess present. When Ms. Guess and her attorney arrived at the house, they walked with Mr. Guess into the basement where the vault was located. Mr. Guess allowed his wife and her attorney to walk into the vault first, and then he pulled out a semiautomatic pistol, pointed it at them, and stated that he was going to kill them. While holding the pistol in his right hand, he struck Ms. Guess twice in the face with his left fist. She and her attorney were ultimately able to talk Mr. Guess into putting the gun down. After Ms. Guess and her attorney were able to leave the house, they drove to seek medical care for her and to contact the police. The State charged Mr. Guess with two counts of felony aggravated assault, and one count of misdemeanor battery. Ultimately, he and the State entered into a written plea agreement. The State agreed to file an amended information charging him with one count of aggravated assault alleged to have been committed against both victims, to which he would plead guilty. The State then recommended that he be sentenced to a withheld judgment and be placed on probation for no more than five years, and he could withdraw his guilty plea if the district court was unwilling to impose a sentence consistent with that recommendation. Mr. Guess pled guilty to the charge, and the court imposed a sentence consistent with the written plea agreement, with the period of probation being five years. Mr. Guess appealed the sentence. Finding no abuse of the court's discretion, the Supreme Court affirmed. View "Idaho v. Guess" on Justia Law

The issue before the Supreme Court in this permissive interlocutory appeal was a district court's determination that the law of the case doctrine prohibited it from making a retroactive determination of Defendant-Respondent Faron Hawkins' mental competency when he stood trial in 2008. A jury convicted defendant of two counts of robbery. He appealed his conviction, and the court of appeals vacated the decision and remanded the matter for a new trial. The appellate court determined that the district court erred by not having defendant undergo a mental health evaluation during his jury trial to determine whether or not he was competent to proceed. Based on the totality of the evidence presented to it, "including admitted exhibits and testimony presented during the competency hearing," the district court found that Hawkins was both presently competent to stand trial and had been competent to stand trial in January 2008. However, the court found that the law of the case required it to retry the case. The Supreme Court held that the language in the trial court record regarding a retroactive competency determination and the State being free to retry Hawkins if he was found presently competent, was not the law of the case. Because there was no legal analysis on the subject of retroactive competency determinations and no factual discussion from the Court of Appeals as to why one would not be possible in this case, the Supreme Court read that court's conclusory statement as an acknowledgement that it had no record on which to base a retroactive competency determination. Therefore the Court reversed the district court and remanded the case for further proceedings. View "Idaho v. Hawkins" on Justia Law

Defendant-Appellant Russell G. Jones appealed his conviction by jury on two counts of rape. The case was initially heard by the Idaho Court of Appeals, which affirmed on one count and reversed on the second. Defendant sought review, which the Supreme Court granted in order to consider the force and resistance necessary with respect to a charge of forcible rape. Given the weight and quantity of the unrefuted evidence across the board, versus the one statement regarding Defendant and the victim, the Court concluded that the district court erred in admitting certain statements made between Defendant and the victim, and that the admission of that statement was harmless. There was insufficient evidence on the element of resistance to support the conviction of forcible rape on Count II so the Court did not consider the issue of force. The conviction on Count II was accordingly reversed. View "Idaho v. Jones" on Justia Law

Defendant-Appellant Robert Barton, Jr. was found guilty by jury of solicitation of perjury. Defendant, the victim of aggravated battery, was charged with solicitation and conspiracy to commit perjury in connection to his testimony in the battery case. On appeal, Defendant argued that the jury should have been instructed on his defense of entrapment, and that such a defense was consistent with his plea of innocence. The State disagreed, arguing that no reasonable view of the evidence would support an instruction for entrapment and that such a defense is incompatible with his plea of innocence. Upon review, the Supreme Court found that the district court did not err when it refused to instruct the jury on the affirmative defense of entrapment, and affirmed the decision. View "Idaho v. Barton, Jr." on Justia Law

In 2006, Woodrow John Grant pleaded guilty to aggravated battery; he successfully completed a period of retained jurisdiction and was placed on probation. In 2009, Grant was charged with possession of methamphetamine, domestic battery, aggravated assault, and unlawful possession of a firearm. Grant's appointed counsel moved to withdraw, stating that Grant had reneged on an agreed-upon plea bargain and that communications between them had broken down. The district court denied the motion. Later, Grant pled guilty to possession of a controlled substance and domestic battery, and admitted to violating the terms of his probation. The district court considered a letter and live testimony from the victim of Grant's domestic battery, in which the victim expressed her opinions on Grant's crime, character, and the sentence that would be proper for him. Thereafter, the district court sentenced Grant to five years fixed and five years indeterminate for domestic battery, to be served concurrently with a sentence of two years fixed and three years indeterminate for possession of methamphetamine. The district court revoked Grant's probation and executed his previously suspended sentence of four years fixed and six years indeterminate. The two new sentences were to be served consecutively to the reinstated 2006 sentence. Grant requested leniency in three I.C.R. 35 motions, which the district court denied. Grant appealed, arguing that the district court erred by refusing to allow his counsel to withdraw, by considering the victim's impact statements in their entirety, and by refusing his requests for leniency. Finding no error, the Supreme Court affirmed the district court in all respects. View "Idaho v. Grant" on Justia Law

Defendant challenged the trial court's decision to admit expert testimony regarding domestic violence and testimony of an excited utterance following his felony convictions of domestic violence and attempted strangulation. In addition, defendant challenged the deputy prosecutor's actions in soliciting testimony of the defendant's post-custody silence when accused of the crimes and the verdict finding defendant was a persistent violator. Upon review, the Supreme Court found no error and affirmed the district court's judgment. View "Idaho v. Parton" on Justia Law

This case arose from a traffic stop and subsequent arrest of Defendant Phillip James Morgan. A Boise City police officer observed Morgan driving in a way that caused the officer to believe Defendant was trying to avoid him. The officer stopped Defendant after observing that Defendant's vehicle did not have a front license plate. Defendant was subsequently arrested for DUI. He filed a motion to suppress all evidence garnered from the traffic stop, arguing the officer did not have reasonable suspicion to initiate the stop. The district court concluded that although Defendant may not have actually violated traffic laws, the officer had reasonable articulable suspicion to believe that he had done so. Defendant's motion to suppress was denied, and he was convicted of felony DUI after a jury trial. Defendant appealed. Upon review, the Supreme Court reversed, concluding the officer lacked the reasonable, articulable suspicion necessary to justify the traffic stop. The judgment of conviction was vacated and the case remanded for further proceedings. View "Idaho v. Morgan" on Justia Law