Justia Constitutional Law Opinion Summaries

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

Amanda Fletcher was arrested after a police officer, Officer Biagi, noticed her vehicle parked outside a convenience store and discovered she had a warrant for her arrest. Upon arresting her, Biagi requested a drug detection dog to sniff the exterior of her vehicle. The dog alerted to the presence of drugs, leading officers to search the vehicle and find methamphetamine and paraphernalia. Fletcher, who was on probation and had waived her Fourth Amendment rights, moved to suppress the evidence, arguing that the Idaho Constitution provides greater protection against dog sniffs and searches than the Fourth Amendment.The District Court of the Fourth Judicial District of Idaho denied Fletcher's motion to suppress, citing her probation agreement, which included a waiver of her rights concerning searches. Fletcher entered a conditional guilty plea, reserving the right to appeal the denial of her motion. She was sentenced to seven years with two years fixed, but her sentence was suspended, and she was placed on probation for seven years. Fletcher then appealed the decision.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's decision. The court held that exterior sniffs of a vehicle by a drug dog are not considered searches under Article 1, Section 17 of the Idaho Constitution. Additionally, the court found that the automobile exception to the warrant requirement does not impose a heightened standard under the Idaho Constitution. The court concluded that the officers had probable cause to search Fletcher's vehicle based on the drug dog's alert, which was sufficient to establish probable cause for a warrantless search. Thus, the district court's order denying Fletcher's motion to suppress was affirmed. View "State v. Fletcher" on Justia Law

Ammon Edward Bundy was convicted of misdemeanor criminal trespass and misdemeanor resisting and obstructing in two separate cases. In the first case, Bundy was observing a committee meeting at the Idaho State Capitol when the meeting was moved due to a disturbance. The Speaker of the House ordered the Lincoln Auditorium to be cleared, but Bundy refused to leave. He was arrested after going limp and requiring troopers to carry him out. In the second case, Bundy returned to the Capitol the day after his arrest, despite receiving a trespass notice prohibiting him from entering the public areas of the Capitol for one year. He was arrested twice on the same day for entering the building and refusing to leave.The district court affirmed Bundy’s convictions in both cases. The court found that Idaho’s criminal trespass statute was not ambiguous and applied to both public and private property. It also determined that the statute was not unconstitutionally vague or overbroad as applied to Bundy’s conduct. The court rejected Bundy’s arguments that the Speaker of the House and the Director of the Department of Administration had unbridled discretion to revoke access to the Capitol. The court also held that Bundy’s arrest was lawful, and his passive resistance did not provide a defense to the charge of resisting and obstructing.The Idaho Supreme Court reviewed the case and affirmed the district court’s decisions. The Court held that the criminal trespass statute provided adequate notice to Bundy that his conduct was prohibited and did not grant unbridled discretion to law enforcement or other state actors. The Court also found that the trespass notice was clear and not unconstitutionally vague or overbroad. Finally, the Court held that Bundy’s arrests were lawful, and his convictions for resisting and obstructing were supported by substantial evidence. View "State v. Bundy" on Justia Law

In 2021, Aaron Von Ehlinger, a first-year member of the Idaho State House of Representatives, was accused of rape by J.V., a legislative intern. They had dinner together and later went to Von Ehlinger’s apartment, where J.V. alleged that he sexually assaulted her. Von Ehlinger claimed the encounter was consensual. J.V. reported the incident, and a forensic nurse, Ann Wardle, conducted a sexual assault examination, documenting J.V.'s account and collecting evidence. Von Ehlinger was charged with rape and sexual penetration by use of a foreign object.The case proceeded to trial in April 2022 in the District Court of the Fourth Judicial District of Idaho. During the trial, Wardle testified about J.V.'s statements, which were admitted despite objections from Von Ehlinger’s defense on hearsay grounds. J.V. testified briefly but left the courtroom before cross-examination, leading the court to strike her testimony. The jury found Von Ehlinger guilty of rape but acquitted him of the second charge. The district court denied Von Ehlinger’s motion for acquittal or a new trial and sentenced him to 20 years in prison, with 8 years fixed.The Idaho Supreme Court reviewed the case. Von Ehlinger argued that his Sixth Amendment rights were violated by the admission of Wardle’s testimony and that the district court erred in allowing a leading question. The court found that Von Ehlinger failed to demonstrate that the admission of Wardle’s testimony was fundamental error, as his counsel’s failure to object could have been a tactical decision. The court also determined that any error in allowing the leading question was harmless, as Wardle did not answer the question directly. The court affirmed the judgment of conviction, concluding that there was sufficient evidence to support the jury’s verdict. View "State v. Von Ehlinger" on Justia Law

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court's denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith's motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and inventory search of his vehicle were reasonable and conducted according to police procedures. Smith was subsequently convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the State did not meet its burden to show that the police officer's decision to impound Smith's vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. As a result, the evidence obtained from the search was inadmissible, leading to the vacating of Smith's conviction. View "State v. Smith" on Justia Law