Justia Constitutional Law Opinion Summaries

Articles Posted in Idaho Supreme Court - Criminal

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This case involved a question regarding the proper amount of credit for time served to which Christopher Osborn was entitled under Idaho Code section 19-2603, the statute governing rearrest for a probation violation. Osborn violated a no contact order twice, pleaded guilty to the misdemeanor charges, and was given consecutive sentences of 365 days in jail on each count. Both sentences were suspended and he was placed on probation for two years on each count to be served concurrently. He was later arrested for, and admitted to, violating the terms of his probation; he served 106 days in jail from the date of his arrest before admitting the violations. The magistrate court granted Osborn 106 days credit for time served against the first of his consecutive sentences. Osborn then filed a Rule 35 motion seeking credit for time served against both consecutive sentences. The magistrate court denied Osborn’s motion. Osborn appealed to the district court, and it reversed the magistrate court’s denial and granted Osborn credit for time served against both sentences. The State appealed, but finding no error in the district court’s calculation, the Idaho Supreme Court affirmed. View "Idaho v. Osborn" on Justia Law

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Eldon Samuel III appealed after a jury found him guilty of second degree murder for killing his father and first degree murder for killing his brother. Samuel’s younger brother was severely autistic and required significant attention. Both of Samuel’s parents had prescription drug addictions which led to financial problems, criminal charges, and arrests. Throughout Samuel’s childhood the family lived in shoddy, cockroach-infested residences and moved frequently, usually after they had been evicted for not paying rent. Samuel’s mother started abusing pain pills following a car accident when Samuel was 4, became suicidal, and was hospitalized several times. Samuel’s father became addicted to pain pills after he injured his shoulder at work. Samuel’s father began to believe that a “zombie apocalypse” was inevitable. Samuel’s mother testified that Samuel’s father taught him how to kill zombies by playing violent video games, watching zombie themed movies, and training Samuel to use knives and guns. In 2014, officers responded to a 911 call at the Samuel residence that the father had been shot. Samuel would give officers a different version of events that night. Samuel’s father was on medication when he shot a .45 gun outside, believing that a “zombie apocalypse” had begun. Samuel told his father to go back inside. Once his father went inside he pushed Samuel in the chest and told him to leave. Samuel picked up his father’s gun, and when his father pushed him a second time, Samuel shot him in the stomach. Samuel’s father then crawled to Samuel’s brother’s room, leaving a trail of blood on the floor. Samuel did not believe the first shot killed his father and shot him three more times in the head once he reached Samuel’s brother’s room. Samuel got a shotgun and shot his brother while he was under the bed. Samuel reloaded the shotgun and continued to shoot his brother. Samuel then dropped the shotgun and started to stab at his brother with a knife. Samuel moved the mattress off of the bed frame and got a machete. Samuel swung the machete at his brother through the gaps in the wood planks of the bed frame. When his brother tried to climb out from underneath the bed, Samuel hit him in the back of the head with the machete. Samuel continued to swing the machete as hard as he could until his brother stopped talking and was quiet. At that point, Samuel called 911. Originally, the State charged Samuel with two counts of first degree murder. However, after a preliminary hearing, the magistrate court found the State had not established probable cause on the premeditation element for the murder of Samuel’s father. Thus, Samuel was charged with first degree murder for his brother and second degree murder for his father. Samuel challenged the district court’s refusal to suppress certain statements he made to police. He also challenged the sufficiency of the evidence presented against him at trial. Finding these challenges unpersuasive, the Idaho Supreme Court affirmed conviction. View "Idaho v. Samuel" on Justia Law

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Gary Partee was convicted by jury of delivery of methamphetamine, possession of methamphetamine with the intent to deliver, and possession of methamphetamine. Before trial, Partee moved to exclude statements he made to law enforcement officers during an interview in which he admitted multiple deliveries of methamphetamine that were made as result of a confidential informant agreement. The district court denied his motion. Because the Idaho Supreme Court held the agreement was ambiguous, it vacated the portion of the judgment of conviction for delivery of methamphetamine and vacated the order denying the motion in limine. The case was remanded for further proceedings. View "Idaho v. Partee" on Justia Law

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Adam Bodenbach was convicted by jury for first-degree murder and possession of cocaine. On appeal, Bodenbach argued: (1) the district court’s “initial aggressor” jury instruction created reversible error because the instruction was unnecessary, confusing, and misstated Idaho law; and (2) the trial court erred in denying his motion to suppress statements he made shortly after the shooting during a police interview. To the latter contention, Bodenbach argued he did not knowingly and intelligently waive his Miranda rights because he was under the influence of drugs. In addition, Bodenbach argued the district court abused its discretion when it sentenced him. Finding no reversible error, the Idaho Supreme Court affirmed Bodenbach's convictions. View "Idaho v. Bodenbach" on Justia Law

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Eric Livingston Weigle was found guilty by jury of robbing a credit union following a two-day trial. During the trial, the State’s forensic scientist used a PowerPoint presentation to explain how she matched one of Weigle’s known fingerprints to one found on the note used in the robbery. At trial, the presentation was admitted as an exhibit for demonstrative purposes without objection. It was then published to the jury. During its deliberations, the jury asked for a copy of the PowerPoint presentation. Weigle’s counsel objected; however, the district court overruled the objection and provided the jury with the presentation. The jury found Weigle guilty. Weigle appealed his judgment of conviction. The Court of Appeals affirmed. To the Idaho Supreme Court, Weigle argued that giving the presentation to the jury during deliberations was improper and constituted reversible error. Finding no abuse of discretion in allowing the jury to see the presentation, the Supreme Court affirmed. View "Idaho v. Weigle" on Justia Law

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Jersson Neftaly Roque Medina (Medina) was convicted by jury of trafficking heroin and conspiracy to violate the Uniform Controlled Substances Act. The charges were brought through two separate cases that arose out of the same set of facts; the cases were consolidated and tried together. Medina appealed his convictions, arguing: (1) fundamental error occurred when he appeared before the jury in chains; (2) fundamental error occurred when the jury instruction listing possible overt acts made in the furtherance of the conspiracy listed numerous acts that did not constitute a proper basis for him to have been found guilty; and (3) there was insufficient evidence to establish the agreement element of the conspiracy charge. Finding no reversible error, the Idaho Supreme Court affirmed Medina's conviction. View "Idaho v. Medina" on Justia Law

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Chad Schiermeier was convicted by jury of grand theft. DARE/PAL was a non-profit organized “to foster, promote, encourage and increase the knowledge, and understanding of alcohol and drug addictions or related problems.” To further its purpose, DARE/PAL offered outdoor-related group activities during the summer months to children between the ages of nine and sixteen. Some of the activities included hiking, golfing, fishing, rafting, and attending baseball games. The activities were primarily funded by the Blaine County Idaho Sheriff’s Office through drug forfeiture funds and by local philanthropists through donations and grants. Schiermeier was a deputy sheriff for the Blaine County Sheriff’s Office from 1999 to 2015, serving as a middle school resource officer and the director of DARE/PAL; he was appointed as manager of the program in 2002. Following Schiermeier’s appointment as manager, the board slowly became inactive, neglecting its duties and entrusting Schiermeier to handle all things related to DARE/PAL. In July 2015, a charitable group called 100 Men Who Care donated approximately $5,100 to DARE/PAL. Shortly thereafter, the group followed up with Schiermeier’s supervisor, Lieutenant Carpita, to see how their donation had been spent. Carpita in turn asked Schiermeier. Several months went by with vague responses, if any, from Schiermeier. Finally, in November 2015, after more than three months of requests and meetings, Schiermeier provided Carpita with the requested DARE/PAL bank records. After reviewing the records, Carpita became suspicious after he noticed “a lot of cash withdrawals through the ATM . . . during times when the PAL activities were not going on.” Consequently, Carpita decided to have the matter independently investigated by the Idaho State Police. The bank records revealed that from 2009 to 2015, Schiermeier made several extravagant purchases of high-end outdoor equipment and clothing. Following the independent investigation by the Idaho State Police, the State charged Schiermeier with one count of grand theft. Schiermeier appealed his judgment of conviction, arguing the State did not prove the elements of grand theft beyond a reasonable doubt. Schiermeier also argued the district court abused its discretion by imposing an excessive sentence. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Schiermeier" on Justia Law

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Aaron Lantis was charged with the misdemeanor offense of disturbing the peace in violation of Idaho Code section 18-6409. The State alleged he committed the crime by sending sexually suggestive photographs of H.H. (Lantis’ ex-girlfriend) to her employer in an unsuccessful attempt to have her fired During trial, Lantis moved for a judgment of acquittal asserting that the statute did not apply to his actions. The magistrate court denied Lantis’ motion. Lantis was found guilty by a jury and he made the same motion post-verdict, which was likewise denied. He appealed to the district court, asserting the same grounds. The district court agreed with Lantis and vacated Lantis’ conviction, holding that Lantis’ conduct was outside the scope of the statute. The State appealed; the Idaho Supreme Court affirmed the district court. View "Idaho v. Lantis" on Justia Law

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In 2009, a jury convicted Vance Thumm of aggravated battery or aiding and abetting aggravated battery and of being a persistent violator of the law. Thumm pursued a direct appeal, but was unsuccessful. In 2013, through counsel, Thumm petitioned for post-conviction relief. The State responded by filing a motion for summary disposition. The district court eventually granted the State’s motion and dismissed the post-conviction petition. Thumm appealed to the Idaho Supreme Court, alleging: (1) ineffective assistance of counsel at trial, sentencing, and on appeal; (2) a Brady violation; (3) prosecutorial misconduct; and (4) cumulative error. Finding no reversible error, the Supreme Court affirmed the district court’s grant of summary disposition. View "Thumm v. Idaho" on Justia Law

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The State appealed a district court order granting Monica Wolfe’s motion to suppress evidence obtained from a cell phone in her possession.In early 2017, a dog owned by Robert Wolfe and his new wife became unusually lethargic and eventually died. Around that same time, they noticed golf balls in their yard, some of which had been chewed. Because no one in the family played golf and they did not live near a golf course, suspicion arose. As a result, the family initiated an investigation through Animal Control and discovered that the golf balls appeared to have antifreeze residue on them. A veterinarian later confirmed that the dog died due to ingesting antifreeze and golf balls. From this, the family suspected that the dog had been poisoned. Soon after the dog died, Daniel Collins, a man who had dated Robert’s ex-wife, defendant Monica Wolfe, contacted Robert and informed him that he had been solicited by Wolfe to kill Robert and his dog. Robert met with Collins at a restaurant and, unbeknownst to Collins, recorded their conversation. During the conversation, Collins stated that Wolfe asked him to find out when Robert left work so that he could “take [him] out from there.” Regarding the dog, Collins said that he was hoping he could “get to [Robert]” before it died, and that Wolfe’s plan was to mix car antifreeze with meatballs to kill the dog. He further asserted that Wolfe “was asking [him] for help . . . but basically wanted to be the one to have [Robert] underground” because “she [was] angry” with him for obtaining custody of their two kids. After this conversation, Robert contacted the police to report Wolfe and Collins. Wolfe was later interviewed. She also admitted to having a conversation about killing a neighbor’s dog with antifreeze, but denied killing Robert’s dog. Further, she and the detective discussed text messages that were on a cell phone in her possession. The district court held that law enforcement unlawfully seized the phone prior to obtaining a warrant to search it. The State argued the "independent source exception" applied because law enforcement subsequently obtained a valid search warrant that was not tainted by the unlawful seizure, and therefore, the evidence found on the phone should not have been suppressed. The Idaho Supreme Court disagreed and affirmed the district court. View "Idaho v. Wolfe" on Justia Law