Justia Constitutional Law Opinion Summaries

The case concerns an individual who was convicted in 2004 of murdering his wife, setting fire to their home while several children were present, and related offenses. The evidence at trial included proof of premeditation, physical evidence linking him to the arson and murder, and testimony regarding his motives and actions before and after the crimes. The jury found him guilty of first-degree murder and other charges, and he was sentenced to death and consecutive prison terms. Over the following seventeen years, the defendant pursued a direct appeal and three post-conviction petitions, all of which were unsuccessful.After the United States Supreme Court issued a decision in Shinn v. Ramirez in 2022, which limited the ability to introduce new evidence in federal habeas proceedings where ineffective assistance of post-conviction counsel is alleged, the defendant filed a fourth (third successive) petition for post-conviction relief in Idaho’s Fourth Judicial District Court. He argued that Shinn was a new event justifying another post-conviction proceeding and advanced claims of ineffective assistance of counsel. The district court dismissed the petition as untimely under Idaho Code section 19-2719, finding that the claims were not raised within the statute’s 42-day deadline and did not qualify for any statutory exception. The court also rejected attempts to amend the petition to argue for an “actual innocence” exception, equal protection violations, and separation of powers challenges.On appeal, the Idaho Supreme Court affirmed the district court’s summary dismissal. The court held that Idaho law does not recognize an actual innocence exception to the 42-day time limit for post-conviction relief in capital cases, that Idaho Code section 19-2719 does not violate equal protection principles, and that the statute is a limitation period rather than a jurisdictional bar, thus not violating the separation of powers under the Idaho Constitution. The judgment of the district court was affirmed. View "Abdullah v. State" on Justia Law

A man was accused of surreptitiously recording his 13-year-old stepdaughter with his cellphone while she was undressing in the bathroom. His wife reported the incident to police, providing video evidence from a hidden camera that appeared to show him engaging in inappropriate conduct outside his stepdaughters’ bedrooms. Detectives confronted the man at his workplace, and after he indicated he wanted a lawyer, he handed over his cellphone when asked by police. The officers immediately informed him they were seizing the device but did not search it until obtaining a warrant the next day. Upon searching the phone, police found incriminating photos and videos, leading to a grand jury indictment on charges including video voyeurism and sexual exploitation of a child.The District Court of the Fourth Judicial District, Ada County, reviewed the defendant’s motion to suppress the cellphone and its contents, arguing the seizure was a Fourth Amendment violation due to the lack of a warrant or valid exception. At a suppression hearing, the court heard testimony from the detective about his concern that evidence could be quickly deleted if the phone was not seized immediately. The district court denied the motion to suppress, concluding that exigent circumstances justified the warrantless seizure because of the imminent risk that evidence would be destroyed.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s denial of the motion to suppress. The Idaho Supreme Court held that the warrantless seizure of the cellphone was justified under the Fourth Amendment’s exigent circumstances exception due to the risk of imminent destruction of evidence. The court clarified that this exception applied based on the totality of the circumstances and did not create a per se rule for all cellphone cases. The judgment of the district court was affirmed. The court also found that any issues regarding parole conditions were moot due to their removal from the amended judgment. View "State v. Smith" on Justia Law

A law enforcement officer stopped the defendant for traffic violations. During the stop, a certified drug detection dog conducted a sniff of the defendant’s vehicle and alerted near the driver’s door. Based on this alert, the officer searched the vehicle and discovered methamphetamine and drug paraphernalia. The defendant was subsequently charged with drug possession offenses. Prior to trial, the defendant moved to suppress the evidence, arguing that the search was unconstitutional because the drug dog’s field alerts over the previous two weeks had resulted in the recovery of drugs only 43% of the time, suggesting the alert was not a sufficiently reliable indicator of the presence of drugs.The District Court of the Third Judicial District, Canyon County, reviewed the suppression motion. The court considered evidence of the dog’s training, certification, and performance in controlled environments, where the dog had demonstrated 100% accuracy. The district court found that the dog’s performance in controlled settings, along with the officer’s explanations for field alerts that did not yield drugs, established the dog’s reliability under the totality of the circumstances. The court denied the motion to suppress, concluding the dog’s alert provided probable cause for the search. The defendant entered a conditional guilty plea, preserving his right to appeal the suppression ruling.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court properly denied the suppression motion. The Idaho Supreme Court held that under the United States Supreme Court decision in Florida v. Harris, proof of a drug dog’s reliability in controlled certification or training programs can provide sufficient reason to trust its alert. The Court concluded that the dog’s field performance alone does not undermine probable cause when the dog’s training and certification are uncontested and reliable, affirming the conviction. View "State v. Barritt" on Justia Law

A woman was convicted of possessing methamphetamine and drug paraphernalia after police discovered these items during a search of a residence she shared with another individual who was on probation. The search was initiated when a probation officer visited to verify the housemate's residence. The woman answered the door, attempted to refuse entry by shutting the door, but the officer entered regardless and proceeded to search the shared bedroom after both occupants indicated there might be contraband present. The officer found drugs and paraphernalia in the room, and both individuals were charged.Previously, the District Court of the Fourth Judicial District, Ada County, denied the woman's motion to suppress the evidence, rejecting her argument that the search was unlawful under Georgia v. Randolph because she had expressly objected to the entry. The district court also admitted a police body camera video at trial, which included statements from her housemate that allegedly violated her Sixth Amendment confrontation rights under Bruton v. United States. The case proceeded to a joint jury trial, resulting in guilty verdicts for both defendants.The Supreme Court of the State of Idaho reviewed the case. It held that the search was lawful because the probationer's waiver of Fourth Amendment rights as a condition of probation allowed officers to enter and search shared areas, even over the objection of a co-occupant. The Court declined to extend the Randolph rule to probation searches, reasoning that co-tenants of probationers have a reduced expectation of privacy. Regarding the confrontation issue, the Court found that admitting the body camera footage was error under Bruton, but determined the error was harmless due to overwhelming independent evidence of guilt. The Court affirmed the district court’s judgment of conviction. View "State v. Horn" on Justia Law

Police responded to a report of a disturbance at a man’s home, where they learned from his girlfriend that he was a convicted felon in possession of firearms. The man admitted that he knew about the firearms and had purchased two for his children. He led officers through his home, where they recovered three firearms and ammunition. The State charged him with three counts of unlawful possession of a firearm by a convicted felon.The case progressed through the Idaho courts, beginning with the magistrate court, where the man repeatedly stated he could not afford an attorney and wanted “effective assistance of counsel,” rather than representation. The magistrate court suggested he did not qualify for a public defender due to his employment, and the preliminary hearing proceeded with the defendant unrepresented, after which he was bound over to the district court. Throughout proceedings before the district court, the man continued to appear without counsel, filing many pro se motions. Eventually, after much confusion about his wishes, the district court appointed “shadow counsel” to assist him at trial, but continued to treat him as self-represented. The jury convicted him on all counts, and the district court denied his post-trial motions.The Supreme Court of the State of Idaho reviewed the case after the Idaho Court of Appeals affirmed the convictions. The Supreme Court held that the appointment of “shadow counsel” did not satisfy the Sixth Amendment right to counsel because the defendant, not an attorney, controlled and managed his defense. The Court further held that the record did not show the defendant knowingly, intelligently, and voluntarily waived his right to counsel, as required by law. As a result, the Supreme Court vacated the judgment of conviction and remanded the case for further proceedings. View "State v. Knight" on Justia Law

Sheryl Robertson was arrested in Custer County, Idaho, for felony possession of methamphetamine and ultimately pleaded guilty pursuant to a plea agreement. The district court sentenced her to a ten-year term, retained jurisdiction for one year, and later placed her on probation with additional requirements after she admitted to multiple probation violations. These requirements included completing 100 hours of community service and successfully participating in a treatment court program. Robertson entered the Bonneville County Wood Court but encountered issues with the program and requested transfer to a different treatment court. The State subsequently moved to terminate her participation in Wood Court and revoke her probation, alleging further rule violations.Robertson waived her right to a termination hearing in Wood Court using forms that referenced only the treatment court termination, not probation revocation. The district court proceeded directly to disposition on the alleged probation violation, reasoning that Robertson’s waiver in Wood Court extended to her right to a probation-revocation hearing. Robertson was sentenced to a modified term of incarceration, and she appealed. The Idaho Court of Appeals affirmed the district court, finding that the procedures under the Idaho Rules for Treatment Courts (I.R.T.C.) were followed and provided the required due process, but declined to address whether Robertson had received the process required by the Fourteenth Amendment as articulated in Morrissey v. Brewer.The Supreme Court of the State of Idaho reviewed the case and held that Robertson’s waiver of her right to a probation-revocation hearing was not knowing and intelligent, as required by the Due Process Clause of the Fourteenth Amendment. The forms she signed did not clearly communicate that waiving the Wood Court termination hearing also constituted a waiver of the right to a probation-revocation hearing. The Supreme Court vacated the district court’s order revoking probation and imposing a modified sentence, and remanded the case for a probation-revocation hearing. View "State v. Robertson" on Justia Law

The case concerns a man who was convicted of first degree murder with a deadly weapon enhancement and resisting and obstructing an officer after his uncle was found fatally stabbed in the home they shared. The defendant was located by police shortly after the incident, with injuries and physical evidence linking him to the crime. During jury selection, the only Black juror in the venire was removed by the prosecution using a peremptory strike, prompting the defendant, who is also Black, to raise a Batson challenge alleging racial discrimination. The trial court denied the challenge, finding the State’s reasons for the strike—juror distraction due to personal circumstances and apparent disengagement—were race-neutral and not pretextual. The jury ultimately found the defendant guilty, and he was sentenced to 40 years to life.The Idaho Court of Appeals affirmed the conviction, holding that the defendant had not established a prima facie case of discriminatory intent under Batson v. Kentucky. The defendant then sought review by the Supreme Court of the State of Idaho, arguing that the trial court erred in denying his Batson challenge, limiting cross-examination about alternate perpetrators, and restricting his closing argument. He also invoked the doctrine of cumulative error.The Supreme Court of the State of Idaho clarified that, under Hernandez v. New York, once the prosecution offers a race-neutral explanation and the trial court rules on discriminatory intent, the initial prima facie showing under Batson is moot. The court found no clear error in the trial court’s acceptance of the State’s race-neutral reasons for the peremptory strike. The court also held that the trial court did not abuse its discretion in limiting cross-examination or closing argument, and found no cumulative error. The judgment of conviction was affirmed. View "State v. Buck" on Justia Law

A man was involuntarily committed to the custody of Idaho’s Department of Health and Welfare under a state statute governing civil mental health commitments. After his commitment, hospital staff requested police assistance to transport him to another facility. When officers arrived, the man was cooperative and followed all instructions. Before placing him in the patrol car, an officer conducted a search for weapons. During this search, the officer felt an item in the man’s pocket that he suspected was drug-related, not a weapon. The officer reached into the pocket and found a small bag containing methamphetamine, leading to a felony drug possession charge.The Fifth Judicial District Court of Idaho reviewed the man’s motion to suppress the methamphetamine evidence, arguing that the search violated his Fourth Amendment rights. The district court found that the man was cooperative, showed no signs of being armed or dangerous, and that the officer did not have reasonable suspicion to believe he was carrying a weapon. The court concluded that the search was not justified under any recognized exception to the Fourth Amendment’s warrant requirement and granted the motion to suppress. The State’s subsequent motion for reconsideration was denied.On appeal, the Supreme Court of the State of Idaho considered whether the warrantless search of a person in civil protective custody under Idaho Code section 66-329 was permissible under the Fourth Amendment. The court held that the State failed to show the search fell within a well-recognized exception to the warrant requirement or was otherwise reasonable. The court clarified that the “community caretaking” function is not a standalone exception to the warrant requirement and that neither the search incident to arrest nor the special needs exception applied here. The Supreme Court of Idaho affirmed the district court’s order suppressing the evidence. View "State v. Adams" on Justia Law

In the early morning of January 8, 2021, two individuals dressed in black entered Samuel Johns' residence. Patrycia Labombard, a visitor, saw the intruders, one of whom was armed with a handgun. She described one as a teenaged girl or young woman. Labombard was restrained with a zip tie but managed to escape and hide. She heard a fight, yelling, and gunshots. After the intruders left, she found Johns with gunshot wounds. Johns died from his injuries. Police interviewed witnesses, including Johns' mother, Debra Moffat, and family members who suspected Clyde Ewing and his son, Demetri Ewing, due to an ongoing dispute over a stolen pistol and backpack. Surveillance footage showed two individuals on bikes near Johns' house. Clyde and Demetri were arrested, and a search of their motel room revealed incriminating evidence.The District Court of the Second Judicial District of Idaho denied Demetri's motion to suppress evidence obtained from the search and arrest warrants, finding probable cause. The court also admitted statements from Moffat, who had died before trial, over Demetri's hearsay objections. Demetri was found guilty of first-degree felony murder and sentenced to life in prison with 25 years fixed.The Supreme Court of Idaho reviewed the case. The court affirmed the district court's denial of Demetri's motion to suppress, finding sufficient probable cause for the search and arrest warrants. The court also found that Demetri was not entitled to a Franks hearing, as he failed to show that any omissions or misstatements in the warrant affidavits were made intentionally or recklessly. However, the court agreed that admitting Moffat's statements violated the Confrontation Clause but concluded that this error did not affect the trial's outcome due to the substantial evidence against Demetri. The Supreme Court of Idaho affirmed the district court's judgment of conviction. View "State v. Ewing" on Justia Law

Damon Victor Crist was convicted of first-degree kidnapping in Utah in 2006 and was required to register as a sex offender in Utah. In 2022, Crist began working in Idaho but did not register as a sex offender there. An informant tipped off the Idaho State Police (ISP), leading to Crist's arrest for failing to register. Crist argued that Idaho law did not permit the magistrate court to determine that his Utah conviction was substantially equivalent to Idaho’s second-degree kidnapping law, which would require him to register. He also claimed that the statutory scheme was void for vagueness.The magistrate court found probable cause to bind Crist over for trial, determining that his Utah conviction was substantially equivalent to an Idaho registrable offense. Crist filed a motion to dismiss in the district court, arguing that only the ISP’s Bureau of Criminal Identification could make the substantial equivalency determination and that he lacked proper notice of his duty to register. The district court denied his motion, concluding that the magistrate court had the authority to make the determination and that Crist had sufficient notice of his registration requirements.The Supreme Court of Idaho affirmed the district court's decision. The court held that a nonresident’s duty to register as a sex offender in Idaho is triggered by the fact of an out-of-state conviction that is substantially equivalent to an Idaho registrable offense and entry into Idaho for employment purposes. The court also concluded that the statutory and regulatory scheme provided fair notice to Crist and did not grant law enforcement unbridled discretion. Therefore, Crist's arguments were rejected, and the decision of the district court was affirmed. View "State v. Crist" on Justia Law