Justia Criminal Law Opinion Summaries

Defendant Daniel Straub pled guilty to vehicular manslaughter, and as part of his plea, agreed to pay restitution to his victims. After a hearing, the district court determined that Defendant owed $554,506.67 to the decedent's family, primarily for future medical insurance premiums and for five years of lost wages. Defendant appealed the restitution order, arguing that the court unreasonably or illegally interpreted the restitution statutes. Finding that Defendant did not waive his right to appeal the district court's order in his plea agreement, and that the district court abused its discretion in ordering Defendant to pay restitution for the victim's future lost wages, the Supreme Court reversed the order and remanded the case for further proceedings. View "Idaho v. Straub" on Justia Law

Defendant-Appellant Randy McKinney was sentenced to death for first-degree murder, and received sentences for conspiracy to commit murder, robbery, and conspiracy to commit robbery. His death sentence was set aside in a federal habeas proceeding. Defendant and the State reached a sentencing agreement with regard to the murder charge for which he received a fixed life term without possibility of parole to be served concurrently with his other sentences. On appeal, Defendant alleged that he was illegally sentenced, violating the double jeopardy clause of both the state and federal constitutions, as well as Idaho's multiple-punishment statute (repealed in 1995). Upon review, the Supreme Court found no error in Defendant's sentences and affirmed them. View "Idaho v. McKinney" on Justia Law

Defendant Abraham Scraggins appealed two district court orders revoking his probation. Defendant was convicted of sexual battery of a minor in 1993, which required that he register as a sex offender in Idaho. In 2009, the State charged him with failure to register when he moved to Ada County in 2008. Defendant pled guilty and received a unified sentence of ten years, five of which were fixed. The sentence was suspended, and Defendant was placed on probation. Under the terms of his probation, Defendant was to serve time in jail at his probation officer's discretion without prior approval of the court. A month after sentencing, the State moved to revoke Defendant's probation, alleging he violated the terms of probation by drinking alcohol and failing to stay at his registered address for a nine-day period. Later in 2009, the State charged Defendant again with failing to register as a sex offender. In a plea agreement, Defendant admitted to violating the terms of his first probation, and pled guilty to failing to register in the second case. The district court revoked Defendant's probation in the first case, and imposed a unified ten-year sentence, with five and one-half years fixed. Less than two months later, probation officers performing a "residence check" found Defendant had contacted his victim, and that he had consumed alcohol. In lieu of filing a report of violation of his probation, Defendant served ten days of the discretionary jail time previously authorized by the district court. At a disposition hearing, Defendant objected to the district court revoking his probation based on these last violations. He argued that because he "had been punished already for this exact same conduct" by serving discretionary jail time, and because "there [was] no new conduct that he has been found in violation for," that a revocation of probation would be a violation of his due process rights. The district court rejected this argument, and accordingly revoked his probation in both cases. It then ordered that the sentences in both cases be executed. Defendant appealed to the Supreme Court, which consolidated the cases on appeal. Upon review, the Court concluded that nothing the probation officers or district court did "affected any articulable due process right." Accordingly, the Court affirmed the district court's decision to revoke Defendant's probation. View "Idaho v. Scraggins, Jr." on Justia Law

Defendant Todd Sunrier is the father of twin girls who, in December 2008, were about three and one-half years old. One of the daughters mentioned to her aunt that Defendant had "hurt her 'business,'" a term she had been taught to use when referring to her vagina. Law enforcement was contacted; Defendant ultimately admitted that for a year he had been abusing both daughters. Defendant was then charged with two counts of lewd conduct. He pled not guilty and was tried before a jury. The jury found Defendant guilty, and he was sentenced to twenty-five years in the custody of the Idaho Board of Correction, with five years determinate and the remaining twenty indeterminate, concurrent sentences. Defendant appealed when the trial court declined to place him on probation. The appellate court reversed the conviction on the ground that there was no evidence corroborating Defendant's confessions as required by the corpus delicti rule. The State filed a petition for review which the Supreme Court granted. Upon review, the Supreme Court found the corroboration was sufficient and affirmed the judgment of conviction. The Court also overruled its prior decisions adopting the corpus delicti rule. View "Idaho v. Suriner" on Justia Law

In 2009, the State filed a petition against John Doe, charging that he was within the purview of Idaho's Juvenile Corrections Act (JCA) for delivery of a schedule III controlled substance, hydrocodone. The State and Doe's counsel reached an agreement whereby Doe admitted to the charge and, in exchange, the State waived proceedings to bring Doe into adult court. At the conclusion of Doe's sentencing hearing, the magistrate judge memorialized his ruling in a "decree" that was issued that same day. The decree stated, "It is hereby Ordered, Adjudged and Decreed that [Doe] is within the purview of the [JCA] and shall be placed on Formal Probation supervision not to exceed 2 years." In the first year of Doe's probation, he had two probation review hearings, both of which demonstrated good behavior. At Doe's one-year probation review hearing, Doe's counsel argued that the magistrate should convert his formal probation to an informal adjustment. Doe's counsel could not cite any authority for converting the sentence, but believed that the court had broad authority to do so based on the interests of justice. The State objected and argued that the court did not have authority to convert the formal probation to an informal adjustment. Ultimately, the magistrate court stated that it had the authority to convert the sentence and entered a "supplemental decree nunc pro tunc to date of original order," granting Doe an informal adjustment and dismissing the case. The magistrate then issued an Order Supplementing Decree that provided "Formal Probation converted to Informal Adjustment, nunc pro tunc 05/05/09." The State filed an appeal to the district court. The district court affirmed the magistrate court's order. The State timely appealed to the Supreme Court. Because it was improper for the magistrate to convert Doe's sentence, any subsequent dismissal or termination of the improperly substituted informal adjustment could not be upheld. The Supreme Court reversed the district court's order and remanded the case for reinstatement of the 2009 decree. View "Idaho v. Doe (2012-09)" on Justia Law

This case arose out of an appeal of the district court's refusal to grant a dismissal following an evidentiary hearing in 2011. In 1988, Defendant Philip Dieter entered a plea agreement with the State in which he agreed to plead guilty to lewd conduct in exchange for the State's dismissal of two related charges. Subsequently, the court entered an Order of Withheld Judgment and Order of Probation. Following an amended order that enlarged the terms of probation, the district court dissolved and terminated probation in 1992. However, it did not dismiss the case. Defendant argued that the district court should have been required to dismiss the case because the initial order contained a clause that stated the case would be dismissed if Defendant fully complied with his probation terms. He also argued that the district court had no authority to deny the dismissal. Upon review of the district court's decision, the Supreme Court affirmed.

During a traffic stop, police officers searched Defendant-Appellant Steven Clay Anderson's vehicle based on a drug dog's alert on the exterior of the vehicle, as well as other suspicious circumstances. The district court denied Defendant's motion to suppress evidence found during the search, holding that probable cause did not dissipate when the same dog failed to alert a second time when placed inside the vehicle. On appeal, the Court of Appeals affirmed. Upon review, the Supreme Court affirmed: "in the absence of something more to neutralize probable cause, the initial alert, coupled with the surrounding suspicious circumstances, entitled the officers in this case to perform a thorough search of Anderson's vehicle, including the manual search performed following the failed alert. Thus, the district court correctly denied Anderson's motion to suppress the evidence found in that search."

The issue on appeal before the Supreme Court pertained to an order suppressing evidence. A law enforcement officer following two vehicles turned on the overhead lights of his patrol car in order to pull over the lead vehicle. Both vehicles pulled over, and the officer parked his car behind the lead vehicle and several car lengths in front of the rear vehicle. When the officer got out of his car, he walked back to the rear vehicle to tell the driver he was only stopping the lead vehicle. The district court held that by walking towards the rear vehicle, the officer seized its occupants without a reasonable, articulable suspicion that they had violated any law. The Supreme Court reversed: when approaching the rear vehicle, the trooper did not draw his gun or make any hand gestures indicating that the vehicle should not leave, nor did he even shine his flashlight at it. Considering the totality of the circumstances in this case, the trooper did not seize the rear vehicle by walking up to the driver's door. His actions certainly indicated that he wanted to talk to the driver, but the Supreme Court concluded that did not constitute a seizure.

Appellant Richard Leavitt appealed his death warrant. He also appealed the district court's denial of his motion to quash the death warrant. In 1984, Appellant brutally attacked, sexually mutilated and murdered a 31-year-old woman in Blackfoot, in which a jury found him guilty of first-degree murder. In 1989, the Supreme Court affirmed his conviction, but reversed the death sentence because the trial court failed to weigh all the mitigating factors against the statutory aggravating factor that the murder was especially heinous, atrocious or cruel manifesting in exceptional depravity. On remand, the district court held another sentencing hearing and again sentenced Appellant to death. The warrant was issued in 1992, with a scheduled date of execution 23 days later. The United States Supreme Court granted Appellant's stay of execution. In 2000, Appellant was granted the writ of habeas corpus because of an improper jury instruction and ordered the State to retry Appellant. The State appealed, and the Ninth Circuit reversed the habeas order. The case was remanded to determine whether Appellant's resentencing hearing in 1989 violated his constitutional rights. In 2007 on remand, the district court again granted habeas relief. The State appealed in 2011, and the Ninth Circuit again reversed the habeas order. In 2012, Appellant filed a motion for relief from judgment; the Ninth Circuit issued a mandate automatically lifting any stay previously imposed by the habeas court. The habeas court denied Appellant's motion, and denied his request for a stay of execution. Appellant's appeal of that order was pending before the Ninth Circuit, but anticipating the issuance of a new death warrant, he filed notice of Demand for Opportunity to be Heard regarding the Issuance of the Death Warrant in Idaho district court. The court denied the motion because at that time, no stay of execution or death warrant was then pending before any court. Subsequently, the court signed Appellant's death warrant and scheduled his execution. Appellant raised multiple challenges to each procedural stage of his case, from sentencing, habeas relief, constitutional rights violations and the eventual signing of his death warrant. Taking all in turn, the Supreme Court found no errors arising from this case's journey to the Idaho Supreme Court. Accordingly the Court affirmed the district court and declined to stay Appellant's execution.

Petitioner Richard Leavitt petitioned the Supreme Court for a writ of mandamus to direct the Commission of Pardons and Parole (Commission) to schedule a full hearing on his petition for commutation and comply with its rules for such a hearing by publishing notice of the time and place of the hearing in a newspaper of general circulation at least once per week for four weeks prior to the hearing. After the Supreme Court affirmed the issuance of Petitioner's death warrant, the Commission denied Petitioner's request for a hearing. Petitioner asked the Supreme Court to set a date for a hearing wherein the Commission must show cause why a full hearing should not be conducted; if granted, the hearing would effectively stay his execution. Upon review, the Supreme Court concluded that the Commission was not required to grant Petitioner a full, open hearing regarding his commutation petition. Furthermore, Petitioner did not demonstrate that his request for the writ of mandamus or alternative writ should have issued. Accordingly, the Court denied Petitioner's requests.