Justia Criminal Law Opinion Summaries

The case revolves around Jeffrey Marsalis's appeal for post-conviction relief based on claims of ineffective assistance of counsel. Marsalis was convicted of rape in 2009, a decision upheld by the Idaho Court of Appeals. He then filed a petition for post-conviction relief, alleging that his trial counsel was ineffective for failing to advise him of his 120-day speedy trial right under the Interstate Agreement on Detainers and for not hiring an expert witness to support his "blackout defense." The district court denied Marsalis's petition for post-conviction relief.The case was previously reviewed by the District Court of the Fifth Judicial District of the State of Idaho, Blaine County. The district court summarily dismissed Marsalis's petition after concluding that there was not a genuine issue of material fact regarding any of Marsalis's claims. Marsalis appealed the dismissal, and the Supreme Court of the State of Idaho affirmed in part and reversed in part. The Supreme Court concluded that the district court erred in summarily dismissing the claims that trial counsel was ineffective for failing to present an expert witness to discuss the scientific basis behind Marsalis's blackout defense, and for failing to inform Marsalis of his speedy trial rights under the Interstate Agreement on Detainers.In the Supreme Court of the State of Idaho, the court affirmed the district court's judgment. The court found that Marsalis failed to establish prejudice on his ineffective assistance of counsel claim concerning the Interstate Agreement on Detainers' 120-day speedy trial timeframe. The court also found that Marsalis failed to establish prejudice on his ineffective assistance of counsel claim concerning his trial counsel's failure to retain an expert witness. The court concluded that Marsalis failed to demonstrate a reasonable probability that the charges against him would have been dismissed with prejudice had trial counsel asserted his speedy trial rights at the December 1 hearing. The court also concluded that Marsalis failed to demonstrate a reasonable probability that, if an expert had provided some additional explanation concerning the scientific bases for blackouts, the jury would have found him not guilty. Therefore, the court affirmed the district court's dismissal of Marsalis's petition for post-conviction relief. View "Marsalis v. State" on Justia Law

The case revolves around Cyrus Wolf Buehler, who was convicted for aggravated driving under the influence (DUI) after a collision with a motorized bicycle, resulting in severe injuries to the cyclist, Raymond Hanson. Buehler was found to have a blood alcohol concentration (BAC) of .181 and .179 at the time of the incident. He sought to introduce evidence suggesting that Hanson's conduct was a superseding, intervening cause of the collision, arguing that Hanson was speeding, under the influence, and his bicycle lacked a headlight. Buehler also challenged the admissibility of his BAC results, as the officer who administered the test had an expired certification.The District Court of the Sixth Judicial District of the State of Idaho denied Buehler's motions, ruling that the evidence he sought to introduce was irrelevant to the determination of whether his act of driving under the influence had some causal connection to Hanson’s injuries. The court also held that the officer’s lapsed certification did not require exclusion of Buehler's BAC results, as the State could establish the foundation for the admission of the evidence through expert testimony. Buehler's conviction was affirmed.On appeal, the Supreme Court of the State of Idaho upheld the lower court's decision. The Supreme Court held that Hanson's conduct was not relevant to the determination of whether Buehler's act of driving while under the influence had some causal connection to Hanson’s injuries. The court also affirmed the lower court's decision to admit Buehler's BAC results, ruling that the officer's lapsed certification did not affect the validity of the BAC results. The court concluded that the district court did not err in its rulings, and Buehler's judgment of conviction was affirmed. View "State v. Buehler" on Justia Law

The Supreme Court of the State of Idaho vacated a lower court's decision to modify Kenneth Richard Rose, Jr.'s sentence. Rose had pleaded guilty to one count of felony aggravated driving under the influence, and the district court sentenced him to six years in prison with one year fixed. The district court indicated it would reconsider Rose's sentence after his direct appeal and stayed the execution of his sentence. Following the conclusion of Rose's appeal, he moved the district court for a reduction of sentence per Idaho Criminal Rule 35(b). The district court agreed and modified Rose's sentence, leading the State to appeal.The Supreme Court found that the district court did not have jurisdiction to modify Rose's sentence because his Rule 35(b) motion was untimely. The court concluded that the 120-day timeframe for filing a Rule 35(b) motion began when the district court initially entered its judgment, not after Rose's appeal concluded. The court held that the district court's decision to stay the execution of Rose's sentence did not extend the timeframe for filing a Rule 35(b) motion. Thus, because Rose's motion was filed more than three years after his sentence was imposed, exceeding the 120 days permitted by Rule 35(b), the district court did not have jurisdiction to modify his sentence. View "State v. Rose" on Justia Law

The case involves the defendant, Kevin James Van Zanten, who was convicted for felony possession of methamphetamine and misdemeanor driving under the influence. Van Zanten challenged the conviction, arguing that the evidence was obtained unlawfully following a stop of the commercial vehicle he was driving. He claimed the stop was based on regulations adopted by the Idaho State Police, which he argued resulted from an unconstitutional delegation of legislative power.In September 2020, an Idaho State Police Trooper observed a 2005 Kenworth truck driven by Van Zanten. The Trooper noted several violations, including an improperly displayed Department of Transportation number, unsecured hazardous material, and other items on the truck. The truck was stopped, and the driver was identified as Van Zanten, whose driving privileges were found to be suspended. A subsequent search of the truck resulted in the finding of drugs, leading to Van Zanten's arrest.At the trial court, Van Zanten moved to suppress the evidence, arguing that the Trooper had no legal basis to stop him. He asserted that the Trooper initiated the stop to investigate state regulations that were unenforceable because the statutes authorizing those regulations unconstitutionally delegated legislative power. The district court denied his motion, leading to his appeal to the Idaho Supreme Court.The Supreme Court of the State of Idaho affirmed the district court's judgment. It held that the Trooper had reasonable suspicion to stop Van Zanten due to specific, articulable facts, thus justifying the stop. The court noted that the inherent danger associated with unsecured hazardous waste and other violations fell within the community caretaking function of law enforcement, and given the nature of the vehicle Van Zanten was driving, the public interest in safety outweighed the limited intrusion of stopping the vehicle. Consequently, the court did not need to address the constitutionality of the statutes in question. The court affirmed Van Zanten’s judgment of conviction. View "State v. Van Zanten" on Justia Law

In this case, Develin Johnson appealed against the district court's decision that upheld his convictions for domestic battery and false imprisonment. The key issue in the appeal was the admissibility of Johnson's previous misdemeanor conviction for petit theft under Idaho Rule of Evidence 608(b) and whether the probative value of the evidence was substantially outweighed by the risk of unfair prejudice. Johnson argued that the district court erred in affirming the judgment of conviction because his misdemeanor conviction for theft was inadmissible under Idaho Rule of Evidence 608(b) and the probative value of the evidence was substantially outweighed by a danger of unfair prejudice. The Supreme Court of the State of Idaho affirmed the district court's decision, holding that the conduct leading to Johnson's 2013 misdemeanor conviction was probative of his character for truthfulness and that the prejudicial effect of the evidence did not substantially outweigh its probative value. View "State v. Johnson" on Justia Law

In the case before the Supreme Court of the State of Idaho, the appellant, Thomas Eugene Creech, appealed the district court's decision to dismiss his successive post-conviction petition as untimely under Idaho Code section 19-2719. Creech argued that his petition was timely due to the United States Supreme Court’s decision in Shinn v. Ramirez, which he believed represented a triggering event that restarted the forty-two-day period for filing a petition under Idaho Code section 19-2719. Creech was convicted and sentenced to death for the first-degree murder of a fellow prisoner in 1981. He filed multiple appeals and petitions for post-conviction relief, all of which were denied. His current petition relates to his 1995 death sentence.The Supreme Court of the State of Idaho affirmed the district court's decision to dismiss Creech's successive petition as untimely. The court held that the Shinn v. Ramirez judgment did not constitute a triggering event to restart the forty-two-day period for filing a petition under Idaho Code section 19-2719. The court noted that Shinn v. Ramirez interpreted federal law and did not have any bearing on state statutes, such as Idaho Code section 19-2719. Furthermore, the court rejected Creech's argument that the alleged ineffective assistance of his initial post-conviction counsel should excuse his failure to timely raise a trial ineffective assistance of counsel claim. The court held that under existing Idaho law, ineffective assistance of post-conviction counsel does not excuse a failure to raise issues that should have been reasonably known. Therefore, Creech's petition was untimely under Idaho Code section 19-2719. View "Creech v. State" on Justia Law

The Supreme Court of the State of Idaho affirmed the dismissal of a successive post-conviction petition for relief filed by Thomas Eugene Creech, an inmate sentenced to death in 1995 for the murder of fellow inmate David Jensen. The district court had dismissed Creech's petition as untimely under Idaho Code section 19-2719, which requires capital defendants to file any legal or factual challenge to the sentence or conviction that is known or reasonably should be known within forty-two days of the filing of the judgment imposing the death sentence. Creech argued that his death sentence, which was imposed by a judge without the participation of a jury, was unlawful based on the prohibition against cruel and unusual punishment under the U.S. Constitution and the Idaho Constitution. He also claimed that societal norms have evolved to the point where his judge-imposed death sentence is now deemed cruel and unusual punishment. However, the Supreme Court held that Creech failed to articulate a claim based on information he did not know or could not have reasonably known within the forty-two day period, thus upholding the district court's dismissal of his petition as untimely. View "Creech v. State" on Justia Law

The Idaho Supreme Court upheld a conviction of a man named Troy Dale Green for various offenses, including trafficking in methamphetamine and unlawful possession of a firearm. Green appealed his conviction, arguing that the testimony of a detective who had not personally performed the extraction of data from his cellphone violated his rights under the Confrontation Clause of the Sixth Amendment. The court disagreed, ruling that the detective's testimony did not violate Green's rights because the detective had sufficient knowledge and experience to analyze the extracted data and independently conclude that the data came from Green's phone. The court also rejected Green's argument that the text messages from his phone were not properly authenticated under Idaho's rules of evidence. The court found that the detective's testimony, along with that of two other detectives, sufficiently authenticated the text messages. The court affirmed Green's conviction. View "State v. Green" on Justia Law

In the case before the Supreme Court of the State of Idaho, defendant William Parsons was convicted on three felony counts of lewd conduct with a minor under sixteen and one misdemeanor count of disseminating harmful material to a minor. The prosecution's case was largely based on video evidence from two interviews with the minor victim, conducted by a medical social worker at a children's evaluation service that specializes in abuse cases. The victim did not testify at the trial. On appeal, Parsons argued that the admission of the video evidence violated his Sixth Amendment rights under the Confrontation Clause, as he was not given an opportunity to confront his accuser.The court agreed with Parsons, concluding that the videos were submitted to the jury in violation of the Sixth Amendment. The court found that the primary purpose of the victim's interviews was to establish or prove past events potentially relevant to a later criminal prosecution, rather than to provide medical care. Therefore, the statements in the interviews were testimonial in nature. Since the defendant had no prior opportunity to cross-examine the victim, the court held that it was error to admit the videos at trial. The court vacated the conviction and remanded the case for further proceedings consistent with its decision. View "State v. Parsons" on Justia Law

In 2021, Gilberto Flores Rodriguez was found guilty of first-degree murder by a Cassia County jury for the 1995 killing of a 14-year-old girl. After the verdict, Rodriguez filed a motion for a new trial, arguing that the district court abused its discretion by denying his motion for a new trial after information came to light suggesting that a juror may have slept through parts of the trial. Rodriguez's argument was based on the belief that the juror's alleged inattentiveness amounted to juror misconduct and could have prejudiced the defendant. The Supreme Court of the State of Idaho held that Rodriguez failed to meet his burden of establishing by clear and convincing evidence that juror misconduct occurred. The court noted that there was much uncertainty over whether the juror was actually asleep during any stage of the trial. The court further held that even if it were to address the question of prejudice, Rodriguez's motion would still lack evidence. The court concluded that Rodriguez failed to establish the identity and duration of the specific testimony, argument, or instructions the juror missed. As a result, the court affirmed the order of the district court denying Rodriguez’s motion for a new trial. View "State v. Rodriguez" on Justia Law