Justia Criminal Law Opinion Summaries

Prior to voir dire in George Cuenca’s trial for aggravated battery, taking place in the midst of the COVID-19 pandemic, the district court ordered that everyone in the courtroom would wear masks, including witnesses. Cuenca objected that the jury would be unable to assess the witnesses’ facial expressions and demeanor during their testimony, which would make it difficult for the jury to judge the credibility of the witnesses. The district court overruled the objection. The trial proceeded, and the jury found Cuenca guilty. Cuenca appealed, claiming his confrontation right was violated by the district court’s mask order. After review, the Idaho Supreme Court concluded the district court’s order did not violate Cuenca’s confrontation right, and affirmed his judgment of conviction. View "Idaho v. Cuenca" on Justia Law

Wayne Marsh was detained by police after an informant reported witnessing an attempted burglary and described him to dispatch as one of the two suspects. During the investigatory detention that ensued, police discovered a valid, outstanding arrest warrant for Marsh. When a subsequent search incident to Marsh’s arrest was performed, the police found methamphetamine in his pocket. After he was charged with possession of a controlled substance, Marsh moved to suppress this evidence, which the district court denied. On appeal, Marsh argued the informant’s tip did not provide reasonable suspicion to justify the initial warrantless detention because it lacked adequate indicia of reliability. He also argued that the alternative basis for the district court’s ruling, that discovery of the arrest warrant attenuated any illegality of his initial detention, was incorrect because of the heightened protections contained in the Idaho Constitution. Finding neither of these arguments persuasive, the Idaho Supreme Court affirmed the district court's order. View "Idaho v. Marsh" on Justia Law

Gilberto Roman-Lopez was convicted by jury on two counts of sexual abuse of a child and three counts of lewd conduct with a minor. Roman-Lopez argued the Idaho Supreme Court should vacate his judgment and remand for a new trial based on two instances where he contended the district court improperly admitted hearsay evidence. As a preliminary matter, Roman-Lopez challenged the proper standard of review for hearsay rulings. From this, he argued the State would not be able to show that the errors were harmless beyond a reasonable doubt, and that the cumulative effect of the errors deprived him of a fair trial. Apart from alleged errors at trial, Roman-Lopez maintained that remand was necessary because the district court did not redline portions of the presentence investigation report it allegedly accepted. Roman-Lopez’s appeal was initially heard by the Court of Appeals, which affirmed. The Supreme Court affirmed Roman-Lopez’s judgment of conviction and declined to remand the matter to redline portions of the presentence investigation report. View "Idaho v. Roman-Lopez" on Justia Law

In 2021, Paul Greer pleaded guilty to felony domestic battery and was sentenced to a prison term of not less than two and not more than seven years. He appealed, arguing the district court abused its discretion when it: (1) failed to redline two requested corrections to the presentence investigation report ("PSI"); and (2) imposed an unreasonable sentence. The Idaho Court of Appeals rejected Greer’s argument regarding the PSI, holding that the record was insufficient to support the appeal because it included only “the PSI that was created prior to sentencing,” not the actual and potentially erroneous report distributed to the Idaho Department of Correction. The Court of Appeals also concluded that the sentence imposed was not unreasonable. The Idaho Supreme Court concluded the district court abused its discretion when it failed to update the portions of the PSI it previously agreed were inaccurate. The court did not abuse its discretion by imposing a unified term of not less than two and not more than seven years. Judgment was thus reversed in part, affirmed in part, and remanded for further proceedings. View "Idaho v. Greer" on Justia Law

Plaintiff-appellant Robert Stark appealed the dismissal of his petition for post-conviction relief. Stark alleged his trial counsel rendered ineffective assistance for failing to file a motion to suppress the contents of a backpack that was searched incident to Stark’s arrest. The district court dismissed Stark’s ineffective assistance of counsel claim, finding Stark did not show deficient performance or prejudice. The district court found that even if a motion to suppress had been filed, it would have been denied, either because Stark disclaimed ownership of the backpack before it was searched or because the contents of the backpack would have been inevitably discovered. Stark challenged the district court’s ruling by arguing that a motion to suppress would have been granted because: (1) the backpack was not lawfully searched incident to his arrest; (2) the contents of the backpack would not have been inevitably discovered; and (3) his disclaimer of ownership was legally ineffective. Stark thereafter appealed to the Court of Appeals, which affirmed the dismissal. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed it. View "Stark v. Idaho" on Justia Law

Jessie Adams appealed an order to pay $15,053.49 in restitution stemming from his conviction of petit theft. The State charged Adams with two separate counts of grand theft. A jury found Adams guilty of the first charge of grand theft; as to the second charge, the jury acquitted Adams of grand theft but found him guilty of the lesser-included offense of petit theft. The district court ordered Adams to pay $15,053.49 in restitution related to his conviction for petit theft. Adams argued the district court had abused its discretion in ordering restitution in an amount greater than $999.99, “the amount associated with the statutory delineation between grand theft and petit theft.” The Idaho Supreme Court concurred the district court abused its discretion by ordering restitution in excess of $1000. The judgment was therefore vacated and the matter remanded for further proceedings. View "Idaho v. Adams" on Justia Law

Chad Schiermeier appealed the summary disposition of his petition for post-conviction relief. In 2017, Schiermeier was charged and convicted of one count of grand theft for stealing money from the Blaine County Sheriff’s DARE program. Schiermeier, a Blaine County Deputy Sheriff, had been the manager of the program for several years and had spent large sums of the program’s money on various items for his personal use. Schiermeier appealed his conviction and sentence to the Idaho Supreme Court, which then affirmed. In 2020, Schiermeier, through the same private attorney who had represented him during his trial, petitioned for post-conviction relief, arguing that his appellate counsel (a Deputy State Appellate Public Defender) had been ineffective for failing to raise several issues in his direct appeal. The State moved for summary disposition, which the district court granted. Schiermeier timely appealed. Finding no reversible error, the Supreme Court affirmed the district court’s summary disposition of Schiermeier’s petition for post-conviction relief. View "Schiermeier v. Idaho" on Justia Law

Kathryn Adkins appealed her conviction for felony concealment of evidence. Whether the crime of concealment of evidence was a felony depends on whether the investigation or trial to which the evidence related involved a misdemeanor offense or a felony offense. Because the felony status of the underlying offense was a “fact” that increases the maximum sentence that may be imposed, Adkins argued that in a jury trial this must be decided by the jury, not the judge. To this the Idaho Supreme Court disagreed and affirmed the judgment of conviction. The sentence imposed by the district court, however, exceeded the maximum permitted under Idaho Code section 18-2603. The sentence was vacated and remanded for entry of a corrected sentence. View "Idaho v. Adkins" on Justia Law

Darin Ogden was convicted on one count of sexual exploitation of a child and one count of sexual battery. Ogden argued the convictions should have been vacated because of several erroneous evidentiary rulings made by the district court, which deprived Ogden of his constitutional right to confront witnesses and present a defense. Alternatively, Ogden argued his sentences should have been vacated because the court considered unreliable information related to earlier conduct for which he had been acquitted. Ogden also requested that the presentence investigation report be redacted to omit those allegations. The Idaho Supreme Court determined that although the district court did not abuse its discretion by denying Ogden’s first Rule 412(b) motion seeking to introduce evidence of V.H.’s (the victim) sexual history with Michael Roller, it abused its discretion by denying Ogden’s second Rule 412(b) motion seeking to introduce evidence of V.H.’s sexual history with Ty Birchfield. The Court affirmed Ogden's conviction for sexual battery, but vacated his conviction for sexual exploitation of a child, and the case was remanded for a new trial. View "Idaho v. Ogden" on Justia Law

Police apprehended defendant Clarence Lancaster for questioning relating to several ATM thefts in Boise, Idaho. He was later charged and ultimately entered conditional guilty pleas to two felonies: burglary and grand theft. This appeal arose from the denial of his motion to suppress. Lancaster argued that his confession and other evidence should have been suppressed because the arresting officers violated Idaho Code section 19-608 by failing to tell Lancaster the basis of his arrest. He maintains that this statutory violation rendered his arrest an unreasonable seizure under Article 1, Section 17 of the Idaho Constitution. He also argues that the district judge abused its discretion at sentencing by failing to strike an attachment to the Presentence Investigation Report. Finding no reversible error, the Idaho Supreme Court affirmed Lancaster's conviction. View "Idaho v. Lancaster" on Justia Law