Justia Criminal Law Opinion Summaries

Defendant-Appellant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. Defendant raised several issues on appeal pertaining to the sufficiency of the evidence presented against him at trial, and procedural errors that prejudicially lead to his conviction. Taking each of Defendant's issues raised on appeal, and after a review of the trial record and applicable law, the Supreme Court found that the jury was presented with sufficient evidence from which it could reasonably find that Defendant was guilty of first-degree murder, and that the trial court committed no fundamental errors that adversely impacted Defendant's trial. Accordingly, the Court affirmed Defendant's convictions and sentences.

In 2003, Defendant Lonnie Forbes pled guilty to attempted lewd conduct with a minor child under sixteen years of age. The district court withheld judgment three months later and placed Defendant on probation for seven years. As a result of his plea, Defendant was required to register as a sex offender. When Defendant committed the crime, Idaho law permitted him to request to withdraw his guilty plea and have the case dismissed. The district court was given discretion to grant Defendant's request so long as Defendant complied with the terms of his probation. Three years later, the law was amended. Three years after that, Defendant's probation was amended to unsupervised probation, with all other terms of probation still in effect. In 2010 when Defendant met the requirements of his withheld judgment, he moved to set aside his guilty plea and for a restoration of his civil rights. The State opposed Defendant's motion to dismiss, but the district court granted Defendant's request. The State appealed, arguing that the change in the law governing Defendant's sentence and probation barred Defendant's ability to have his case dismissed. Upon review, the Supreme Court held that the district court erred by retroactively applying the amended law to Defendant's case. The district court's decision was vacated and the case remanded for further proceedings.

Defendant-Appellant Matthew Hanson was convicted of aggravated assault. At the sentencing phase, he exercised his Fifth Amendment privilege against self-incrimination and declined to participate in the preparation of the presentence investigation (PSI) report. Defendant later moved the court to order a presentence psychological evaluation. The district court ruled that unless Defendant agreed to participate in the PSI, his motion would be denied on the ground that a defendant may not selectively invoke his Fifth Amendment privilege with respect to different aspects of a single subject. Defendant again declined to participate, and the court denied his motion. Defendant's attorney subsequently requested a competency evaluation, which was also denied. Defendant was sentenced to five years, with three years fixed. He then moved for reconsideration of his sentence, which motion the district court denied. Defendant appealed the district court's denial of his requests for a psychological evaluation and for a competency evaluation. Upon review, the Supreme Court affirmed the district court's denial of Defendant's request for a competency evaluation. However, the Court reversed the district court's denial of Defendant's request for a psychological evaluation because: (1) the record showed Defendant's mental condition would be a significant factor at sentencing; and (2) it incorrectly held that Defendant could not invoke his Fifth Amendment privilege against self-incrimination with regard to the PSI but waive the privilege in order to obtain a psychological evaluation. Accordingly, the Court vacated the district court's judgment and remanded the case for further proceedings.

Defendant-Appellant Simona Manzanares appealed the judgment entered after she pled guilty under a conditional plea agreement. She pled guilty to recruiting a criminal gang member in exchange for the dismissal of a charge for providing a firearm to a criminal gang member. On appeal, Defendant argued that the "Recruiting Provision" (I.C. 18-8504(1)(a)) was unconstitutionally overbroad on its face and as applied for encroaching on the First Amendment right to free association; that the "Firearm Provision" (I.C. 18-8505) was unconstitutionally overbroad as applied for punishing her "expressive conduct," and unconstitutionally vague on its face and as applied for failing to adequately define "gang member," as well as being unconstitutional under the Second Amendment of the federal and under Article I, Section 11 of the state constitution. Defendant raised additional constitutional claims, and argued that the evidence presented against her at the preliminary hearing was insufficient to support the charges she faced. Upon careful consideration of Defendant's arguments, the Supreme Court concluded that the "Recruiting" and "Firearm" provisions were not unconstitutionally overbroad nor were they unconstitutional as they applied to Defendant. As such, the Court upheld Defendant's conviction pursuant to her conditional plea agreement.

Defendant-Appellant Daniel Johnson petitioned the district court for an exemption from sex offender registration requirements. The district court determined that the 2009 amendments to the Idaho Sexual Offender Registration Notification and Community Right-to-Know Act (SORA) precluded such exemption and therefore denied his petition. On appeal, Defendant argued that the district court’s application of SORA was unconstitutional. Because Defendant filed his petition in his already-dismissed criminal case, the Supreme Court concluded the district court lacked jurisdiction to consider the matter. The Court therefore vacated the district court’s decision.

Defendant John Joseph Delling appealed his conviction based on his conditional pleas of guilty to two counts of second-degree murder. Defendant was initially charged with two counts of first-degree murder for the deaths of David Boss and Brad Morse. These counts were later amended to second-degree murder. Shortly after being charged, Defendant's counsel motioned for a mental health evaluation to determine whether Defendant was fit to proceed and able to aid in his own defense. Defendant requested that the Supreme Court reconsider and overrule its decision in "State v. Searcy" (798 P.2d 914 (1990)), to find that Idaho's abolition of the insanity defense was unconstitutional. Defendant also asserted that the district court abused its discretion and imposed excessive sentences. Upon careful review of the applicable legal authority and the arguments presented in Defendant's appellate brief, the Supreme Court concluded Defendant had not provided any argument that showed the precedential cases to be wrongly decided, unwise, or unjust. By looking at each argument individually, none of Defendant's constitutional rights were infringed by the abolition of the insanity defense. Furthermore, the Court also found that the sentence imposed by the district court was reasonable and not an abuse of discretion.

Defendant John Schulz appealed his conviction of felony domestic battery and the attempted strangulation of his fifteen-year-old daughter. Both charges required the state to prove that the daughter was Defendant's "household member" as defined by the applicable statute. The district court granted Defendant's motion to dismiss based on the fact that she did not fall within that definition. Because the Supreme Court found that the definition of "household member" plainly limited the application to "intimate partners" and thus, did not extend to a child living with her father, the Court affirmed.

Defendant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. In 2007, a jury convicted him for the stabbing death of Cassie Jo Stoddart. Defendant raised multiple issues on appeal, among them, he challenged the sufficiency of the evidence presented at trial. Furthermore, Defendant alleged multiple errors at trial prejudiced him from receiving a fair trial. Upon careful review of the trial court record, the Supreme Court found that the jury was provided with sufficient evidence from which it could reasonably find beyond a reasonable doubt that Defendant was guilty of first-degree murder, and that the trial court did not err in its rulings at trial. Accordingly, the Court affirmed Defendant's convictions and sentences.

Cassie Jo Stoddart was murdered in 2006. Defendant Brian Draper, who was sixteen years-old at the time of Stoddartâs murder, and Torey Adamcik, also a juvenile, were arrested and charged with murder and conspiracy to commit murder. Both were tried as adults, and convicted during separate trials. Defendant was sentenced to a term of fixed life imprisonment for the murder charge and a life sentence with thirty years fixed for the conspiracy charge. Defendant raised seven issues on appeal: 1) the jury instructions for both murder and conspiracy relieved the State of proving all elements of the crimes and violated his right to due process of law; 2) his fourth police interview should have been suppressed as his parents were not present at the interview; 3) the jury instructions and the district courtâs failure to suppress the interview, even if individually harmless, cumulatively constitute reversible error; 4) the sentences should be vacated because the investigatorâs presentence report was biased; 5) Defendant's fixed life sentence for murder violated the Idaho and U.S. Constitutionsâ prohibition of cruel and unusual punishment; 6) the district courtâs sentences constituted an abuse of discretion; and 7) the district courtâs denial of Defendant's motion under Idaho Criminal Rule 35 to modify his sentences constituted an abuse of discretion. Upon review of the trial court's record, the Supreme Court only found error in the jury instruction pertaining to Defendant's conspiracy charge, but affirmed the trial court in all other respects. The Court vacated Defendant's conviction on conspiracy to commit first degree murder and remanded the case for a new trial on that charge.

This case arose from Defendant Diego Morales Peregrinaâs conviction on two counts of aggravated battery and two firearm enhancements; one for each battery. Peregrina argued on appeal of his sentence that there was insufficient evidence to support the district courtâs "implicit" finding that the crimes arose out of divisible courses of conduct, and that even if there was, the State had the burden to submit the issue of divisibility to the jury and prove it beyond a reasonable doubt. Upon review of the trial court record, the Supreme Court found that no instruction was requested by either Peregrina or the State regarding I.C. 19-2520E, which states that when two crimes "arise out of the same indivisible course of conduct," the defendant "may only be subject to one (1) enhanced penalty." The district court sentenced Peregrina as follows: ten years fixed for the first count of aggravated battery; ten years fixed for the second count of aggravated battery consecutive to the first count; ten years indeterminate enhancing the sentence in the first count; and ten years indeterminate enhancing the sentence in the second count, both consecutive to the previous counts. Peregrina was also sentenced to five years fixed for his conviction for unlawful possession of a firearm, to run concurrent with the other sentences, with credit for two hundred days served. The Supreme Court found that the State's failure to submit the issue of divisibility to the jury and to prove it beyond a reasonable doubt. The Court remanded the case back to the district court for further proceedings.