Justia Criminal Law Opinion Summaries
Articles Posted in Idaho Supreme Court - Criminal
Hall v. Idaho
In 2004, a jury found Petitioner Erick Hall guilty of first-degree murder, kidnapping and rape. Petitioner was sentenced to death. Petitioner appealed his conviction, and was appointed a public defender. In 2005, Petitioner petitioned the district court for post conviction relief. In that proceeding, the district court limited contact between Petitioner's counsel and the jurors that convicted him. Petitioner moved for reconsideration. In 2006, Petitioner moved to depose his trial attorneys and their investigator. The court allowed the deposition of trial counsel, but denied leave to depose the investigator. Petitioner's petition for post conviction relief was ultimately denied. On appeal to the Supreme Court, Petitioner challenged all of the district court's denials pertaining to the interview and deposition of jurors and key witnesses so that he could mount a successful appellate petition for relief. The Supreme Court found that the district court did not abuse its discretion in denying Petitioner's requests. The Court affirmed the district court's decision on all issues.
Idaho v. Ellington
Defendant Jonathan Ellington appealed his conviction for murder and aggravated battery. He argued on appeal to the Supreme Court that prosecutorial misconduct, evidentiary errors, a biased jury and the "cumulative error doctrine" entitled him to a new trial. The Supreme Court found merit to several of Defendant's claims. The Court found that the district court abused its discretion when it denied Defendant a new trial after evidence came to light that the State's sole rebuttal witness provided false testimony at trial. The Court vacated Defendant's conviction and sentence, and remanded the case for a new trial.
Fields v. Idaho
Petitioner Zack Fields appealed the dismissal of his application for post conviction relief. In 1988, Petitioner was sentenced to death for the stabbing death of Mary Vanderford. Petitioner argued that he was wrongly accused and that DNA test results and affidavits of trial witnesses supported his argument. The district court ordered nineteen latent fingerprints from the murder scene to be run through the national fingerprint database and to have DNA testing of substances found on Petitioner and the victimâs clothing and underneath her fingernails. Testing determined that the fingerprints did not belong to Petitioner, nor did any of the substances contain his DNA. On appeal to the Supreme Court, Petitioner argued that he was entitled to an inference that the victim scratched her attacker because the attacker was close enough to stab her. With no DNA evidence of Petitioner recovered from the murder scene, Petitioner contended the district court erred by not viewing the DNA and fingerprint evidence âin a light most favorable toâ Petitioner. The Supreme Court found that there was ânothing but speculation supporting the claim that the scrapings from the victimâs fingernails came from her attacker. We therefore uphold the dismissal of [Petitionerâs] claim . . . because the DNA test results, in light of all admissible evidence, do not demonstrate that [Petitioner] is not the person who committed the murder.â