Justia Criminal Law Opinion Summaries

Thomas Hooley appealed a district court’s summary dismissal of his petition for post-conviction relief. In 2014, Hooley was convicted of aiding and abetting aggravated battery and kidnapping in the first degree. Hooley petitioned for post-conviction relief in 2019, claiming: (1) he was actually innocent; and (2) the prosecution withheld favorable evidence. The district court concluded that Hooley’s actual innocence claim was time-barred and further concluded the claim failed on the merits. While the district court found that Hooley’s evidence claim was timely, the court ultimately determined the claim failed on the merits, and dismissed the petition without an evidentiary hearing. Finding no reversible error in the summary disposition, the Idaho Supreme Court affirmed the district court. View "Hooley v. Idaho" on Justia Law

Erick Hall appealed the district court’s dismissal of his successive petition for post-conviction relief regarding his death sentence, which he received for the murder of Lynn Henneman in September 2000. Hall contended his appellate counsel had been ineffective for failing to raise certain claims related to the guilt and sentencing phases of his original trial in his first petition for post-conviction relief. Hall further asserted that the district court presiding over the original petition for post-conviction relief committed several reversible errors that appellate counsel failed to raise on appeal to the Idaho Supreme Court. The district court dismissed Hall’s successive petition in its entirety. Finding no reversible error in that decision, the Supreme Court affirmed. View "Hall v. State" on Justia Law

Darin Ogden appealed his conviction for possession of methamphetamine and drug paraphernalia. During a consensual encounter, officers searched Ogden’s vehicle outside of a business and arrested Ogden for felony possession. At trial, the State introduced redacted police officer on-body video showing the search. The nature and scope of the video became an issue during trial. The jury found Ogden guilty on both counts. At sentencing, Ogden objected to portions of a presentence investigation (PSI) report that included investigative and third-party records from two pending unrelated cases, and seven allegedly inaccurate statements in the PSI. Ogden’s objections to the PSI were largely denied. Ogden appealed to the Court of Appeals, which affirmed, and he then petitioned for review by the Idaho Supreme Court, arguing: (1) a response he gave to officers that was recorded on the video, but redacted, should have been admitted; and (2) it was error for the district court to permit irrelevant evidence to be presented to the jury. Given the accumulation of these alleged multiple errors, Ogden argued that his conviction had to be vacated. The Supreme Court determined district court erred by allowing the State to present evidence that the district court determined was not relevant, but that this error was harmless. "A single error does not require Ogden’s conviction to be vacated." Further, the Supreme Court found the district court abused its discretion in failing to redline the portions of the PSI it had agreed to correct, but did not abuse its discretion in declining to redline portions describing conduct Ogden was acquitted of. The case was remanded to district court to ensure that the victim’s medical records were stricken from the PSI. View "Idaho v. Ogden" on Justia Law

Officers from the Boise Police Department arrested Eduardo Plata Iniguez (“Plata”) outside his home for misdemeanor driving under the influence (“DUI”) without a warrant, and without witnessing the commission of the alleged crime. Upon his arrest, Plata was transported to jail where evidentiary breath testing was administered. At the jail, Plata failed to provide an adequate breath sample. Thereafter, officers procured a warrant from an on-call magistrate judge for a search of Plata’s blood, performed a blood draw at the Jail, and obtained an evidentiary sample of his blood. The State charged Plata with misdemeanor DUI (second offense), and Plata moved to suppress the blood draw evidence as a product of his unlawful arrest under Idaho v. Clarke, 446 P.3d 451 (2019). The Idaho Supreme Court concluded Plata made an initial showing of a causal nexus; Idaho’s exclusionary rule did not include a reasonable “mistake of law” exception; and the State did not argue another established exception applied (e.g., inevitable discovery or attenuation). Thus, the blood draw evidence should have been suppressed as derivative fruit of Plata’s illegal arrest, and the decision of the district court was reversed. View "Idaho v. Plata Iniguez" on Justia Law

Kirby Dorff appealed the denial of his motion to suppress evidence obtained after a police drug-sniffing dog jumped onto the exterior surface of his vehicle. Dorff argued the dog’s contact with his vehicle was a trespass, and therefore, an unlawful “search” under the common law trespassory test as articulated in United States v. Jones, 565 U.S. 400 (2012), applied in Idaho by Idaho v. Howard, 496 P.3d 865 (2021) and Idaho v. Randall, 496 P.3d 844 (2021). The Idaho Supreme Court found the drug dog intermeddled with Dorff’s vehicle when it jumped onto the driver side door and window, planted two of its paws, and sniffed the vehicle’s upper seams. Accordingly, law enforcement conducted a warrantless and unlawful “search” of Dorff’s vehicle by way of its drug dog. The denial of Dorff’s motion to suppress was reversed, his conviction was vacated, and this case was remanded to the district court for further proceedings. View "Idaho v. Dorff" on Justia Law

Following a jury trial, Travis Leavitt was convicted for statutory rape of a 17-year-old girl. He was 34 years old at the time of the incident. After the trial had begun, the State disclosed new evidence regarding Leavitt’s past criminal record, which the district court admitted. Leavitt challenged his conviction on the basis that the court allowed impermissible propensity evidence to be presented to the jury, including evidence of his criminal sexual history. Additionally, Leavitt asserted that even if the admission of such evidence were proper under Rule 404(b), the State failed to show good cause for its late disclosure of the evidence disclosed after trial began and evidence that he was a felon and a sex offender should have been barred as unfairly prejudicial under Rule 403. Leavitt’s appeal was initially heard by the Idaho Court of Appeals, which vacated his conviction and remanded the case for a new trial in an unpublished decision. The Idaho Supreme Court granted the State’s petition for review of the Court of Appeals’ decision. Though its reasoning differed, the Court reached the same result, concurring the trial court erred, and affirming the appeals court's outcome. View "Idaho v. Leavitt" on Justia Law

In April 2018, a teller working at CapEd Credit Union called the Boise Police Department to report a suspicious situation: a man came into the credit union, made a large cash deposit, exited the building, and then changed clothes in the parking lot. The man subsequently spoke with two other men in the parking lot. The teller reported that the men’s behavior made credit union employees nervous. Officers from the Boise Police Department responded to the credit union's call and detained one man in the parking lot. As the man in the parking lot was being detained, Officer Will Reimers arrived at the scene and proceeded into the credit union without speaking to the officers in the parking lot. As he waited for an employee to unlock the doors, Reimers observed two men, Patrick Maahs and Jordon Korona, standing at the teller counter. Reimers was dressed in full police uniform. One man left the counter and proceeded down a nearby hallway, then the other man followed. An employee informed Reimers that both men had gone into a bathroom, even though they were informed that it was a single person bathroom. Reimers took a position just behind a wall at the head of the hallway leading to the bathroom and called for backup. Once Maahs left the bathroom, he was subdued by police and eventually arrested on firearms and methamphetamine possession charges. Maahs moved to suppress the evidence seized from the search of his car on the basis that officers had conducted a de facto arrest and that his seizure was unsupported by probable cause or reasonable suspicion. The Idaho Supreme Court found the district court erred in denying the motion to suppress: Maahs was arrested without probable cause, and items found in his care should have been suppressed as "fruit of the poisonous tree." Maahs' judgment of conviction was vacated and the case remanded for further proceedings. View "Idaho v. Maahs" on Justia Law

Defendant-appellant Diwakar Singh was convicted for felony domestic violence. Prior to Singh’s trial, the State identified an error in the preliminary hearing transcript. The district court, citing its inherent authority to correct errors in the record, corrected the transcript after listening to the official recording of the preliminary hearing. Singh appealed the district court’s decision to correct the transcript and admit the correction as an exhibit at his trial. "Singh has not explained, nor can we perceive, why the magistrate court would be in a better position to correct the patent error in this case, which is clearly evident from the official audio recording of the proceeding. Under the circumstances here, where the district court listened to the official recording of the preliminary hearing and there is no genuine dispute between the parties as to what was said on that recording, it would add expense and delay to the criminal process to require remand to the magistrate court so that it could listen to the same audio recording a second time before the transcript could be corrected." The Idaho Supreme Court concluded the district court did not err in correcting the patent error in the preliminary hearing transcript. View "Idaho v. Singh" on Justia Law

Jonathan Hernandez pled guilty to second-degree murder. He petitioned for post-conviction relief, arguing his trial counsel was ineffective for promising Hernandez he would not receive a sentence of more than ten to fifteen years. Following this alleged promise from his attorney, Hernandez signed a written plea agreement and guilty plea advisory form. At the change of plea hearing, the district court placed Hernandez under oath and confirmed that Hernandez and his attorney had reviewed the guilty plea advisory form. The district court later sentenced Hernandez to a unified term of life in prison, with a minimum period of confinement of forty-five years. Following an unsuccessful appeal, Hernandez petitioned for post-conviction relief. At the hearing on the State’s motion for summary judgment, the district court found that any error Hernandez’s counsel made was cured by a colloquy that took place between the district court and Hernandez at the change-of-plea hearing. There, the district court confirmed answers Hernandez gave on the plea agreement form and the potential sentence Hernandez faced. The district court granted the State’s motion for summary judgment and dismissed Hernandez's case with prejudice. Finding no reversible error in the dismissal of Hernandez's petition for relief, the Idaho Supreme Court affirmed the district court. View "Hernandez v. Idaho" on Justia Law

Jorge Rodriquez was convicted of domestic battery with traumatic injury in the presence of a child. His first trial ended with a hung jury. In the second trial, the jury found Rodriquez guilty of the charge. The district court sentenced Rodriquez to eighteen years, with eight years determinate. Rodriquez directly appealed his conviction, and the Idaho Court of Appeals affirmed. Rodriquez then petitioned for post-conviction relief alleging ineffective assistance of counsel, prosecutorial misconduct, and the denial of his right to a fair trial following various rulings from the district court. After reviewing his petition, and several dispositive filings, the district court served Rodriquez with a notice of intent to dismiss on October 6, 2020. Rodriquez amended his petition the next day, and the district court served Rodriquez with its second notice of intent to dismiss on October 15, 2020. Rodriquez filed a supplemental brief five days after his response was due. The district court dismissed the petition after concluding Rodriquez failed to timely respond. Rodriquez appealed to the Idaho Court of Appeals, which affirmed. Rodriquez then petitioned for review to the Idaho Supreme Court, which was granted. Finding no reversible error, the Supreme Court affirmed the district court’s judgment summarily dismissing Rodriquez’s petition. View "Rodriquez v. Idaho" on Justia Law