Justia Criminal Law Opinion Summaries

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

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