Charboneau v. Idaho

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Petitioner Jaimi Charboneau was granted a new trial, and the State appealed. Charboneau murdered his ex-wife, Marilyn Arbaugh, in 1984. Her two daughters, Tiffnie and Tira, witnessed the crime, and they both testified during his trial. The State moved for summary judgment to dismiss this petition for post-conviction relief on the ground that it was barred by Charboneau’s third petition for post-conviction relief, and the district court denied that motion. It ultimately granted Charboneau a new trial. It held that a letter written by Tira was admissible pursuant to Idaho Rule of Evidence 804(b)(3) as a statement against interest (she admitted testifying falsely at Charboneau’s trial) and pursuant to Idaho Rule of Evidence 803(24), the catch-all exception to the hearsay rule. The court also ruled that another statement was admissible. The State timely appealed, and Charboneau cross-appealed. The Idaho Supreme Court concluded the district court erred in granting a new trial: the issues raised in this case were raised and rejected in Charboneau’s third petition for post-conviction relief, and he could not raise them in this subsequent petition in a different form. The Supreme Court reversed the district court’s judgment and remanded this case to the district court with directions to dismiss the petition with prejudice. View "Charboneau v. Idaho" on Justia Law