Justia Constitutional Law Opinion Summaries

Articles Posted in Idaho Supreme Court - Criminal
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After a jury found Jesus Garcia guilty on charges related to a deadly night-club incident, the district court ordered restitution against Garcia in the amount of $162,285.27. In Idaho v. Garcia, 462 P.3d 1125 (2020) (“Garcia I”), the Idaho Supreme Court reversed the district court’s restitution order after determining the district court had not properly considered Garcia’s future ability to repay that amount. On remand, the district court held a second restitution hearing, weighed evidence from before and after remand, and determined Garcia had the foreseeable ability to pay the restitution amount. The district court then reinstated the original order in full. Garcia appealed, arguing the district court’s decision ignored the Supreme Court’s restitution holding in Garcia I, and was not supported by substantial evidence. Finding no reversible error, the Supreme Court affirmed the trial court. View "Idaho v. Garcia" on Justia Law

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Gerald Pizzuto, Jr., was convicted of two brutal murders and sentenced to death in 1986. After the Idaho Commission of Pardons and Parole voted 4-3 to recommend that Pizzuto’s death sentence be commuted to life without the possibility of parole, Idaho Governor Brad Little rejected the recommendation, thereby allowing Pizzuto’s death sentence to remain in effect. Pizzuto challenged the Governor’s action by filing an Idaho Criminal Rule 35(a) motion to correct his sentence, and a sixth petition for post-conviction relief. The district court granted both Pizzuto’s motion and petition after finding Idaho Code section 20-1016 was unconstitutional. The State appealed to the Idaho Supreme Court. Finding Idaho Code section 20-1016 was a constitutional expression of the authority granted to the Legislature, the Supreme Court determined the district court erred in granting both Pizzuto’s Rule 35(a) motion and his petition for post-conviction relief. “Both decisions were based on the erroneous grounds that Governor Little lacked authority to reject the Commission’s clemency recommendation because Idaho Code section 20-1016 is unconstitutional. … Because the 1986 amendment to Article IV, section 7, authorizes the legislature to govern the Commission’s commutation powers ‘by statute,’ and Idaho Code section 20-1016 is a proper expression of that authority, we reverse the district court’s orders and remand Pizzuto’s cases for further proceedings.” View "Idaho v. Pizzuto" on Justia Law

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Defendant-appellant Ricky Weaver appealed his conviction for solicitation of murder. The State contended Weaver offered to pay a fellow inmate to murder his girlfriend while they were both being held in the Elmore County Detention Center. Weaver was subsequently charged and convicted by a jury. During his trial, Weaver attempted to elicit testimony from another prisoner, Michael Dean, that Wallace had told Dean that he made up the murder-for-hire story against Weaver in an attempt to try to get a “deal” from the prosecutor in his own case. The district court excluded the evidence on the grounds that Dean’s testimony was hearsay and inherently unreliable based on Dean’s own statements. On appeal, Weaver asserts the district court erred by excluding Dean’s testimony because the anticipated testimony: (1) was relevant because it tended to make it more probable that Wallace had not testified truthfully but instead had tried to set Weaver up in order to secure a “deal” from the prosecutor; (2) fit within the “state of mind” exception to the hearsay rule; (3) was proper impeachment of Wallace’s credibility; and (4) had probative value not outweighed by the possibility of unfair prejudice. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Weaver" on Justia Law

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Melanie Hall appealed a district court’s modification of a no contact order. In 2015, the State of Idaho charged Hall with felony stalking of her ex-husband, and aggravated assault. Based on the charges, the district court entered a no contact order and set it to expire in 2017. In January 2016, a jury found her guilty of felony stalking, but returned a verdict of not guilty on the aggravated assault count. In March 2016, the district court entered a judgment of conviction, sentencing Hall to a five year unified sentence with the first two fixed. The court also entered an amended no contact order prohibiting Hall from contacting her ex-husband and their two minor children. The new no contact order was sent to expire on March 28, 2021. Hall moved to amend the no contact order twice: once to allow written communication, and another to allow Hall to send Christmas presents to the children. Two days before the order was set to expire, the State moved to extend the order, explaining that Hall’s victims were concerned with the order’s expiration, and that a new charge of violating the no contact order was pending before the district court. An extension was ultimately granted, and Hall appealed, arguing the district court lacked subject matter jurisdiction to modify the order because it had expired by the time the district court entered its order. The Idaho Supreme Court determined the district court had the authority to amend the no contact order because the State’s motion to extend the expiration date was timely filed. Accordingly, the extension was affirmed. View "Idaho v. Hall" on Justia Law

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Jesus Blancas was stopped by Idaho State Police Sergeant Chris Elverud. Elverud suspected Blancas of driving under the influence and administered four breath tests, but only one produced a valid result. That test indicated that Blancas’ blood alcohol content (BAC) was nearly three times the legal limit. Elverud then took Blancas to a hospital to collect a blood sample for testing. Blancas refused to consent to the blood draw, and Elverud attempted to reach an on-call magistrate judge to obtain a warrant. After failing to reach the on-call magistrate judge, Elverud instructed hospital staff to draw Blancas’ blood under the exigent circumstances exception to the warrant requirement. The Idaho Supreme Court concluded that warrantless blood draw violated Blancas’ Fourth Amendment rights because the State failed to prove there was insufficient time to obtain a warrant, and therefor, failed to prove exigent circumstances justified the blood draw. View "Idaho v. Blancas" on Justia Law

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Brian Hollist challenged a district court’s denial of his motion to suppress evidence. Hollist was arrested in Idaho Falls after an officer approached him while he was sleeping on a canal bank. The officer was responding to check on Hollist's welfare. After advising the officer he did not need medical assistance, Hollist attempted to leave several times; however, each time the officer insisted that Hollist remain. When Hollist declined to identify himself, the officer handcuffed him and ordered him to sit down on the grass. The officer later discovered that Hollist had an outstanding warrant for his arrest. Following his arrest, officers found a glass pipe with white residue and a bag with a small amount of methamphetamine inside. Before trial, Hollist moved to suppress the methamphetamine and pipe, arguing: (1) the officer was not performing a community caretaking function at the time he was detained; (2) the officer did not have reasonable suspicion to detain him; and (3) the eventual discovery of the arrest warrant did not purge the taint of his unlawful seizure. The district court denied Hollist’s motion to suppress. Hollist timely appealed. The Idaho Supreme Court concluded the officer did not have a reasonable suspicion to detain Hollist, and the officer's unlawful seizure of Hollist was not sufficiently attenuated from the discovery of contraband. The district court's denial of Hollist's motion to suppress was reversed and the matter reversed for further proceedings. View "Idaho v. Hollist" on Justia Law

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This case involved an investigatory detention of Jeremey Huntley based on a series of tips, corroborated in part, from a known confidential informant that Huntley was trafficking methamphetamine into Idaho. Huntley moved to suppress the methamphetamine evidence found on his person and in his vehicle found during a search after the stop. The district court granted Huntley’s motion after concluding the officers lacked reasonable suspicion for the stop and that it was unlawfully prolonged. The State appealed. The Idaho Supreme Court reversed, finding that the tips and corroboration supplied the officers with reasonable suspicion to stop Huntley, and the stop was not unlawfully extended because the detectives never deviated from the original purpose of the stop. View "Idaho v. Huntley" on Justia Law

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The State appealed the district court’s order granting Sunny Riley’s motion to suppress evidence obtained when a drug dog alerted on her vehicle while she was being cited for a traffic offense. Riley’s motion was granted by the district court after it concluded that the police officer’s deviations from the traffic stop measurably and unlawfully extended the duration of Riley’s seizure under the Fourth Amendment. The Idaho Supreme Court reversed, finding that while there were two deviations from the initial course of this traffic stop, the combined deviation was insufficient to change the overall length of the stop beyond the time when the drug dog alerted on the vehicle. When this occurred, it gave rise to a reasonable suspicion of drug activity and allowed officers to continue to investigate. View "Idaho v. Riley" on Justia Law

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Juan Jimenez filed a pro se petition for post-conviction relief and requested that counsel be appointed to represent him under Idaho Code section 19- 4904. In November 2018, Jimenez was charged with felony possession of a controlled and possession of contraband in a correctional facility. Pursuant to a plea agreement, he entered an Alford plea to the controlled substance charge and a judgment of conviction was entered in December 2018. The district court sentenced Jimenez to a three-year unified sentence with the first six months de terminate, to run consecutively to the sentences he was already serving. For his post-conviction relief petition, the district court appointed an attorney to represent Jimenez but limited the scope of his counsel’s representation to a single claim in the petition: his Rule 35 ineffective assistance of counsel claim. Jimenez argued the district court erred by limiting appointed counsel’s representation. To this, the Idaho Supreme Court agreed. Accordingly, the Supreme Court vacated the judgment dismissing Jimenez’s petition, and remanded for further proceedings. View "Jimenez v. Idaho" on Justia Law

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The issue presented for the Idaho Supreme Court's review in this case arose from a March 2020 traffic stop where a single officer, without having reasonable suspicion that a crime involving the passenger was afoot, checked the passenger for outstanding warrants. The officer used her patrol vehicle’s computer and received a “hit” for a warrant and arrested the passenger. After the arrest, the officer discovered methamphetamine in the passenger’s purse, the rear of the patrol vehicle where the passenger was seated, and on the passenger’s person. The district court ordered the methamphetamine evidence suppressed after concluding the officer unlawfully extended the traffic stop by checking the passenger for outstanding warrants absent reasonable suspicion or a safety justification particular to that stop. The Supreme Court reversed and remanded the trial court's judgment, finding that the Fourth Amendment permits law enforcement to check passengers for outstanding warrants as a matter of course during traffic stops because of officer safety concerns. View "Idaho v. Wharton" on Justia Law