Justia Constitutional Law Opinion Summaries

In the case before the Supreme Court of the State of Idaho, defendant William Parsons was convicted on three felony counts of lewd conduct with a minor under sixteen and one misdemeanor count of disseminating harmful material to a minor. The prosecution's case was largely based on video evidence from two interviews with the minor victim, conducted by a medical social worker at a children's evaluation service that specializes in abuse cases. The victim did not testify at the trial. On appeal, Parsons argued that the admission of the video evidence violated his Sixth Amendment rights under the Confrontation Clause, as he was not given an opportunity to confront his accuser.The court agreed with Parsons, concluding that the videos were submitted to the jury in violation of the Sixth Amendment. The court found that the primary purpose of the victim's interviews was to establish or prove past events potentially relevant to a later criminal prosecution, rather than to provide medical care. Therefore, the statements in the interviews were testimonial in nature. Since the defendant had no prior opportunity to cross-examine the victim, the court held that it was error to admit the videos at trial. The court vacated the conviction and remanded the case for further proceedings consistent with its decision. View "State v. Parsons" on Justia Law

In June 2021, Kenneth Bernard Kimbley, III, was convicted on four counts of lewd and lascivious conduct and sentenced to four concurrent sentences, each for a determinate period of not less than fifteen years and an indeterminate period of not more than fifteen years, for a total unified sentence not to exceed thirty years. Kimbley appealed his conviction, presenting multiple arguments to the Supreme Court of the State of Idaho.The court rejected Kimbley's argument that his Sixth Amendment right to a public trial was violated when his trial was livestreamed due to COVID-19 restrictions. The court determined that Kimbley had not objected to the livestreaming at the time and had therefore waived his right to object to it on appeal.Kimbley also argued that his right to counsel was violated as he was unable to communicate with his attorney during pretrial hearings in which his attorney appeared remotely. However, the court noted that Kimbley hadn't raised this issue at the lower court, nor had he demonstrated how this alleged violation affected the outcome of his trial.Kimbley further contended that the lower court erred by admitting evidence of his flight from prosecution and his firearm possession. The Supreme Court found that evidence of Kimbley's flight was relevant and admissible as it indicated a consciousness of guilt. Evidence of Kimbley's firearm possession was also deemed admissible as it was introduced by Kimbley's own counsel for the purpose of impeachment.Lastly, Kimbley argued that the prosecutor committed misconduct during closing arguments by discrediting a witness who had invoked her Fifth Amendment right. However, the court declined to consider this argument as Kimbley hadn't objected to the prosecutor's comments at the time and had not adequately argued that these comments constituted a fundamental error on appeal.In conclusion, the Supreme Court of the State of Idaho affirmed the judgment of the lower court, rejecting all of Kimbley's arguments on appeal. View "State v. Kimbley" on Justia Law

Following the State’s dismissal of criminal charges against him, Nickolaus Oldenburg moved the district court to seal the criminal court file pursuant to Idaho Code section 67-3004(10). The State did not contest the motion. Nevertheless, the district court concluded that it did not have the authority to seal Oldenburg’s case file under section 67-3004(10) and, therefore, could not grant his request. As a result of its analysis, the district court denied Oldenburg’s motion. The Idaho Supreme Court held the district court correctly concluded that the legislature could not independently vest the district court with the authority to seal Oldenburg’s court file. "The control of court records resides within the prerogative of this Court, and this Court has adopted I.C.A.R. 32 to govern a defendant’s request to seal court records. ... When the statute is procedural, it is viewed as an attempt 'to control this Court’s processes' and is classified as an impermissible overreach into the authority of this Court to develop its own procedures." Thus, the district court correctly found that Idaho Code section 67-3004(10) impinged on the Supreme Court’s prerogative to make its own rules which governed its own procedure. Accordingly, the decision of the district court was affirmed. View "Idaho v. Oldenburg" on Justia Law

Rodney Harrell appealed his conviction for trafficking in methamphetamine, trafficking in marijuana, and possession of drug paraphernalia. Harrell argued his convictions should have been vacated because: (1) the district court erred in denying his motion to suppress; and (2) the district court erred in denying his objection to the reduction of peremptory challenges imposed by the Idaho Supreme Court’s emergency order adopted in response to the COVID-19 pandemic. Finding no reversible error, the Supreme Court affirmed Harrell’s judgment of conviction. View "Idaho v. Harrell" on Justia Law

While a passenger during an unrelated traffic stop, defendant-appellant Audrey Monroe was recognized by a Bingham County Sheriff’s deputy as having an outstanding warrant. Pursuant to the warrant, the deputy attempted to take her into custody. In the course of the arrest, Monroe refused to release her phone, which was secured on her finger by a phone ring holder. As Monroe’s resistance escalated, she fell to the ground and began violently kicking, making contact with the officer. Ultimately, she was secured in the police cruiser. The incident was captured on video by the arresting officer’s body camera. For her conduct during the arrest, Monroe was charged with felony battery on a police officer. During trial, Monroe asked the district court for jury instructions regarding two misdemeanor offenses, asserting that they were lesser included offenses of the crime charged. The district court declined to give either instruction. At the conclusion of the trial, the jury found Monroe guilty of the felony charge. On appeal, Monroe argued the district court erred in failing to give the requested lesser included jury instructions. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Monroe" on Justia Law

While on patrol, Deputy Sheriff Brock Katseanes discovered an unattended car parked in the parking lot of a public boat launch. The car was unlocked, and its trunk and front windows were open. Katseanes learned the car was registered to April Ramos. Katseanes was eventually joined by five additional officers and a canine to search the surrounding area for Ramos, but they were unsuccessful in locating her. Due to his previous encounters with Ramos, Katseanes believed the car likely contained illegal drugs. The canine conducted a drug sniff; the dog did not alert during its sniff of the car’s exterior. The officers subsequently impounded the car and then conducted an inventory search of it prior to having the car towed. During the inventory search, the officers found methamphetamine and drug paraphernalia. Ramos was charged with possession of a controlled substance and possession of drug paraphernalia. She moved to suppress all evidence found during the inventory search of the car. The district court denied her motion. Ramos conditionally pleaded guilty to possession of a controlled substance but retained her right to appeal the denial of her motion to suppress. As a result of the plea agreement, the State dismissed the possession of drug paraphernalia charge. Ramos timely appealed, and the Idaho Court of Appeals affirmed. The Idaho Supreme Court reversed the district court's judgment. "Absent clear instruction from the United States Supreme Court, we decline to expand Opperman’s 'community caretaking' rationale to include potential theft or property damage to the vehicle as an acceptable reason to impound a vehicle. ... an officer’s concern that the car will be subject to theft or property damage if it is not impounded—no matter how well-founded the concern may be—is irrelevant to the analysis as to whether the decision to impound the car is reasonable under the Fourth Amendment." The case was remanded to the district court to determine whether the decision to impound Ramos’s car passed constitutional muster. View "Idaho v. Ramos" on Justia Law

Edo, a dog used by the Boise Police Department to detect controlled substances, alerted on defendant-respondent Shawna Pendleton’s vehicle during a traffic stop. Videos of the incident raised questions about the reliability of Edo’s performance. Through a series of discovery requests, Pendleton sought additional videos and police reports from past stops to challenge Edo’s reliability in detecting drugs. The district court, over repeated objections from the State, ultimately granted her motion to compel the evidence on finding it material to her defense. On appeal, the State argued the district court abused its discretion by denying its motion for reconsideration because: (1) Pendleton failed to establish that the requested evidence was material to her defense; (2) the production of four-months’ worth of Edo’s reports and videos was unduly burdensome, and (3) not all of the requested evidence was within the prosecutor’s possession, custody, or control. The Idaho Supreme Court concluded the State failed to show an abuse of discretion in compelling production of the videos and reports regarding Edo and his handler for the four months prior to Pendleton’s arrest. The Supreme Court affirmed the district court’s determination that the evidence sought by Pendleton was material, not unduly burdensome, and in the “possession, custody or control” of the prosecution pursuant to Idaho Criminal Rule 16. View "Idaho v. Pendleton" on Justia Law

In 2017, Guy Bracali-Gambino pleaded guilty to possession of major contraband in a correctional facility. On direct appeal, the Idaho Court of Appeals, in an unpublished opinion, affirmed his conviction and sentence. Bracali-Gambino subsequently filed a petition for post-conviction relief, arguing in relevant part that his trial counsel had coerced him into pleading guilty, provided erroneous legal advice regarding sentencing enhancements for persistent violators, and failed to investigate the prosecution’s evidence. Bracali-Gambino contended, that considering these errors, his trial counsel had been ineffective. Except for a portion of one of Bracali-Gambino’s claims (Claim II), the district court summarily dismissed his claims relevant to this appeal without conducting an evidentiary hearing. The district court also ultimately dismissed the one remaining claim following an evidentiary hearing. The Idaho Supreme Court affirmed the district court’s dismissal of Bracali-Gambino’s petition for post-conviction relief. Claim II failed because Bracali-Gambino specifically disclaimed, while under oath at his change of plea hearing, that anyone (which included his defense counsel) had coerced or pressured him into pleading guilty. Claim III failed because Bracali-Gambino’s conclusory allegations were not sufficient to show that he was prejudiced by the purported erroneous legal advice. Finally, Claim VI failed because Bracali-Gambino did not provide a sufficient explanation as to how certain testimony would have contradicted the State’s evidence that he attempted to possess major contraband. View "Bracali-Gambino v. Idaho" on Justia Law

After methamphetamine was found on his person during a pat search, Appellant John Doe was charged with felony possession of a controlled substance and two related misdemeanors under the Juvenile Corrections Act (“JCA”). Doe moved to suppress this evidence as the product of an unlawful search under the Fourth Amendment, which the magistrate court denied. Doe then sought permission to appeal the magistrate court’s decision to the district court, sitting in its intermediate appellate capacity. When the magistrate court denied permissive appeal, an intermediate appeal was filed with the district court. The district court dismissed Doe’s appeal, concluding that a permissive appeal was not available to Doe because he had not yet been adjudicated of any violation under the JCA. Doe then appealed to the Idaho Supreme Court, arguing: (1) he was “within the purview” of the JCA; and (2) Idaho Code section 20-528 permitted an appeal as a matter of right to a juvenile defendant whose motion to suppress has been denied. The Idaho Supreme Court concluded the plain language of the statute did not permit a juvenile defendant to file this type of interlocutory appeal. Accordingly, the Court affirmed the district court’s dismissal of John Doe’s interlocutory appeal. View "Idaho v. John Doe" on Justia Law

An Idaho district court denied Jared Head’s motion to strike certain evidence supporting a restitution order. Jared and his wife, Teresa, worked as onsite managers at the Village Inn Motel in Malad City, Idaho. Following an investigation by the Oneida County Sheriff’s Office, Jared and Teresa were separately charged with grand theft. After pleading guilty to grand theft, Jared was ordered to pay $24,535.23 in restitution for allowing people to stay at the motel without paying, and for accepting rent payments that he did not relinquish to the motel owners. Relevant to this appeal, some of the State’s evidence supporting the restitution amount related to a specific hotel guest, S.G. Just before resting its case at the restitution hearing, the State disclosed that S.G. had been found incompetent to stand trial in an unrelated criminal case several months earlier. Jared then sought to strike any testimony, exhibits, and statements related to S.G., arguing the State withheld exculpatory evidence in violation of his due process rights under Brady v. Maryland, 373 U.S. 83 (1963) and in violation of his Sixth Amendment right to confrontation under Crawford v. Washington, 541 U.S. 36 (2004). The district court denied Jared’s motion after concluding that his due process claim was moot because Brady did not apply to restitution hearings, which the district court couched as civil proceedings. Jared appealed, arguing the district court erred in applying an incorrect legal standard to deny his motion to strike. Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Idaho v. Head" on Justia Law