Justia Constitutional Law Opinion Summaries

In 2014, Thomas Kralovec was arrested by Boise City Officer Tad Miller for public intoxication and resisting and obstructing arrest. While he was being transported to jail, Kralovec was antagonistic. He cursed, insulted, and threatened Officer Miller. Upon arrival at the jail, Kralovec was met by four deputies. Kralovec remained combative and non-compliant during the intake process. The four deputies took turns restraining Kralovec to search him and remove his handcuffs so that he could be left alone in the cell. The deputies placed Kralovec on a concrete bench in the cell in a prone position with his legs in a “figure four leg trap” with his face to the wall. At some point during the search, Kralovec’s right leg came free and kicked out, knocking a microphone loose from the clip on one deputy’s shirt and allegedly striking another in the shoulder. The incident was recorded by a camera in the holding cell. The State filed an information charging Kralovec with one count of battery on a peace officer, later amending it to charge Kralovec with battery on a correctional officer. State filed notice of its intent to introduce audio evidence of Kralovec’s arrest and transport to jail to show Kralovec’s knowledge and intent pursuant to Idaho Rule of Evidence 404(b). Kralovec objected, arguing that the evidence was either not relevant, or its probative value was substantially outweighed by its prejudicial effect. The district court concluded that the evidence was res gestae evidence temporally connected with the alleged battery and had a tendency to explain Kralovec’s alleged misbehavior during the booking process. The district court further concluded that the evidence was admissible under Idaho Rule of Evidence 404(b) as it was relevant to Kralovec’s intent. Kralovec was ultimately convicted on one count of battery on a correctional officer. On appeal, Kralovec argued: (1) the State failed to present constitutionally sufficient evidence upon which a reasonable trier of fact could have found that the State sustained its burden of proving the essential elements of the crime beyond a reasonable doubt; (2) the district court abused its discretion when it admitted audio evidence of Kralovec’s encounter with Officer Miller as res gestae and under Idaho Rule of Evidence 404(b); and (3) the sentencing judge abused his discretion by refusing to review the trial transcripts and exhibits prior to sentencing. Finding no error in the district court’s judgment of conviction, the Supreme Court affirmed. View "Idaho v. Kralovec" on Justia Law

The question before the Supreme Court in this matter was whether exigent circumstances existed to justify a warrantless blood draw. Defendant-appellant Daniel Chenobieff argued the blood draw violated his constitutional protection against unreasonable searches and seizures and, consequently, that the district court erred in affirming the magistrate court’s denial of his motion to suppress the evidence obtained in the blood draw. The district court specifically pointed to the prosecutor’s attempt to obtain a warrant through the on-call magistrate who could not be reached. The district court also made reference to the delay resulting from Chernobieff's refusal to perform field sobriety tests, but in doing so the court erred. Any delay caused by Chernobieff's exercise of his Constitutional rights may not be considered. The court concluded that the magistrate considered the totality of circumstances and that the magistrate’s findings were supported by substantial evidence. The Supreme Court concurred with the district court. "Even excluding the delay related to the field sobriety tests, there was substantial evidence to support the magistrate’s findings. Therefore, we find that the district court did not err in affirming the denial of the motion to suppress the results of the blood draw." View "Idaho v. Chernobieff" on Justia Law

Tarango Deforest Padilla was convicted of two counts of grand theft and was found to be a persistent violator. He appealed his conviction, and it was affirmed by the Idaho Court of Appeals in an unpublished opinion. He later filed a petition for post-conviction relief, contending that his attorney provided ineffective assistance in failing to file a motion to suppress. The district court dismissed that petition. Defendant again appealed. Finding that no such motion would have been successful, the Supreme Court affirmed the district court’s dismissal of Padilla’s petition for relief. View "Padilla v. New Mexico" on Justia Law

James Clark was charged with misdemeanor trespass in the Idaho Industrial Commission office in Boise. At the close of the State’s evidence at trial, Clark moved for a judgment of acquittal, which the court denied. The jury found Clark guilty and he appealed to the district court. The district court affirmed the denial of the acquittal motion and upheld the jury verdict. The Court of Appeals reversed, finding that the judgment of acquittal should have been granted. The State appealed. Finding that the Court of Appeals erred in reversing the district court's judgment, the Supreme Court reversed. View "Idaho v. Clark" on Justia Law

Edgar Farfan-Galvan appealed his conviction for felony driving under the influence (“DUI”). Farfan-Galvan moved to dismiss or remand the charge, based upon his claim that one of the prior DUI convictions upon which the State relied to enhance the charge from a misdemeanor to a felony was obtained in violation of his Sixth Amendment right to counsel. The district court denied the motion. The Supreme Court reversed. The record before the district court did not contain any indication that Farfan-Galvan had waived the right to counsel in the prior 2010 case. Therefore, that conviction could not serve as the basis to enhance the charge to a felony. The district court’s decision denying his motion to dismiss or remand. was reversed, and in light of this, the Court vacated Farfan-Galvan’s conviction. View "Idaho v. Farfan-Galvan" on Justia Law

Alik Takhsilov appealed the district court’s summary dismissal of his petition for post-conviction relief, arguing that his trial counsel was ineffective for failing to request a competency evaluation prior to his entry of guilty pleas. During the pendency of his underlying criminal case, Takhsilov was deemed incompetent to proceed and was transferred to Idaho State Hospital South pursuant to Idaho Code section 18-212. Three months later, he was found to have regained competency, and he was returned to the district court. Takhsilov then entered guilty pleas to one count of robbery under Idaho Code section 18-6501 and one count of burglary under Idaho Code section 18-1404. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Takhsilov v. Idaho" on Justia Law

Jonathan Hill was convicted for felony driving under the influence (DUI). He raised one issue on appeal. Over an unsuccessful hearsay objection, the deputy sheriff who conducted field sobriety tests (FSTs) of Hill was permitted to testify as to what he had been taught regarding the presence of vertical nystagmus. Hill’s appeal challenged that evidentiary ruling. The Supreme Court found that even if the testimony was relied upon for the basis of an expert opinion, it was improper to disclose the facts upon which Deputy Smith based his opinion. This error was not harmless, and as such, the Supreme Court vacated Hill's conviction and remanded the matter for a new trial. View "Idaho v. Hill" on Justia Law

Defendant-appellant John Linze, Jr. appealed after he was convicted for conviction of possession of methamphetamine. On appeal, he argued the district court erred by refusing to suppress evidence obtained by police during a traffic stop. Specifically, Linze argued that: (1) the traffic stop was impermissibly extended in order to allow time for the drug detection dog to arrive; (2) the traffic stop was impermissibly extended in order to allow the drug detection dog to conduct a sweep; and (3) the alert of the drug detection dog was insufficient to establish probable cause to search the vehicle because the dog was unreliable. Linze’s initial appeal before the Court of Appeals resulted in his conviction being vacated. That court held that the time during which the drug detection dog conducted its sweep of the vehicle was an impermissible extension of the original traffic stop. The Supreme Court agreed with that reasoning and affirmed the appellate court. The district court’s judgment was vacated (as was the order of probation), and the order denying Linze’s motion to suppress was reversed. View "Idaho v. Linze" on Justia Law

Cesar Sepulveda appealed after a jury found him guilty of felony intimidating a witness, misdemeanor domestic battery, injury to a child, and two counts of attempted violation of a no contact order. Sepulveda contended that his right to confront witnesses, his right to present a defense, and his right to be free from double jeopardy were violated and that his convictions should have been vacated. Finding no such violations, the Supreme Court affirmed Sepulveda's convictions. View "Idaho v. Sepulveda" on Justia Law

Scott Ostler was convicted of three counts of lewd conduct with a minor child under sixteen, and one count of sexual abuse of a child under the age of sixteen. This appeal related only to a single count of lewd conduct: Ostler claimed that the State violated his right to due process by adding an additional lewd conduct charge following a mistrial. The Court of Appeals vacated Ostler’s conviction for the additional felony, agreeing that the State violated Ostler’s right to due process. The Supreme Court affirmed the district court's judgment of conviction: "The proper avenue for Ostler to seek relief is in post-conviction proceedings." The Court ruled that Ostler “may still file a petition for post-conviction relief proceedings in order to ascertain whether defense counsel’s failure to object to the alleged error constituted ineffective assistance of counsel.” Ostler’s claim of prosecutorial vindictiveness required further factual development as to why the State added an additional lewd conduct charge. View "Idaho v. Ostler" on Justia Law