Justia Constitutional Law Opinion Summaries

When asked about recent negative behavior, defendant-appellant Jason Roberts’ fifteen-year-old son informed his mother that she would understand if she saw the signs that Roberts “was sexually hurting” him. A Children at Risk Evaluation Services (CARES) facility interview was ultimately arranged for the child. At the beginning of the interview, the interviewer informed the child that he would speak to a nurse after the interview. Upon hearing this, the child appeared taken aback. The interviewer clarified that “they’re just going to see how tall you are and how much you weigh.” The child responded, “Okay, I thought they were going to test me for [sexually transmitted infections]. I was like, ummm.” During the CARES interview, the child detailed how Roberts had sexually abused the child starting when he was seven or eight years old. The child related that the last episode of sexual abuse occurred about two and one-half years prior to the CARES interview. While discussing the instances of sexual abuse, the child stated that after the abuse, he struggled with “suicidal stuff” that resulted in the child being “locked up.” The child indicated that after his release, he again struggled with “suicidal stuff” because the abuse continued. He admitted during the interview that he was having “a couple” thoughts about suicide, described his preferred method of self-harm, and indicated that at the time of the interview, he felt like engaging in self-harm a “little bit.” After the CARES interview, Roberts was indicted by a grand jury for two counts of lewd conduct with a minor child under age sixteen. At trial, the district court admitted a recording of the CARES interview over Roberts’ objection. In doing so, the district court found that the child was capable of making statements for medical purposes and that “there is little reason to doubt [the child’s] motivation in making the disclosures.” Both the child and Roberts testified at trial. Ultimately, the jury found Roberts guilty of both counts. Roberts appealed. Finding no abuse of discretion in admitting the CARES interview, the Idaho Supreme Court affirmed Roberts' judgment of conviction. View "Idaho v. Roberts" on Justia Law

Jane Doe appealed a district court’s decision to uphold the magistrate court’s judgment that Doe committed a battery—placing Doe within the purview of the Juvenile Corrections Act. Doe argued the magistrate court erred by using and applying the self-defense law reflected in Idaho Criminal Jury Instructions 1517 and 1518, instead of Idaho Code section 19-202A, Idaho’s “stand your ground” statute. Doe contended the statute’s legal standards differed from Instructions 1517 and 1518, and that the statutory standards should have been applied to her self-defense claim. To this, the Idaho Supreme Court disagreed: the "stand your ground" statute codified aspects of Idaho self-defense law that existed for over 100 years at common law, without abrogating those aspects it left uncodified. Thus, the Supreme Court held the district court did not err in upholding the magistrate court’s use and application of the pattern instructions, which presumptively reflected the elements of self-defense at common law. View "Idaho v. Jane Doe (2021-38)" on Justia Law

Respondent Camille Pool pleaded guilty to misdemeanor DUI in 2020. In May 2020, approximately two months following the onset of the coronavirus pandemic, Pool was sentenced at a hearing conducted over Zoom which she attended remotely. The State recommended Pool be sentenced to supervised probation with suspended jail time. The magistrate court ultimately sentenced Pool to 180 days in jail with 177 days suspended, granted her a withheld judgment, and placed her on supervised probation for 18 months. The magistrate court went on to explain some of the terms Pool would need to accept in order to receive probation. The following day, the magistrate court entered a written Judgment of Conviction: a form document for DUI cases. A paragraph next to the probation check box listed possible probation terms, which included: "Defendant specifically waives his/her 4th Amendment right to warrantless search of his/her person, vehicle, or residence by any law enforcement or probation officer." The form included a line for the defendant’s signature, but Pool was not personally present in the courtroom and, therefore, did not sign the Judgment. Instead, on the signature line, someone handwrote “mailed to defendant 5/27/2020.” While on probation, Pool failed to appear for drug and alcohol testing and failed to comply with other terms of her probation. On April 14, 2021, three probation officers went to Pool’s residence to conduct a residence check. One officer spoke with Pool, mentioned the Fourth Amendment waiver, and Pool indicated that she understood. Pool’s residence was searched and drugs and drug paraphernalia were found. Pool was charged with felony possession of a controlled substance and a misdemeanor charge for possession of drug paraphernalia. Pool moved to suppress the items seized and the statements she made during the search of her home, arguing that, among other things, she had not waived her right against search and seizure under Article I, section 17 of Idaho’s Constitution and, therefore, the search violated her rights under the Idaho Constitution. The Idaho Supreme Court determined the search was lawful and reversed the district court's decision granting the motion to suppress. View "Idaho v. Pool" on Justia Law

Thomas Hooley appealed a district court’s summary dismissal of his petition for post-conviction relief. In 2014, Hooley was convicted of aiding and abetting aggravated battery and kidnapping in the first degree. Hooley petitioned for post-conviction relief in 2019, claiming: (1) he was actually innocent; and (2) the prosecution withheld favorable evidence. The district court concluded that Hooley’s actual innocence claim was time-barred and further concluded the claim failed on the merits. While the district court found that Hooley’s evidence claim was timely, the court ultimately determined the claim failed on the merits, and dismissed the petition without an evidentiary hearing. Finding no reversible error in the summary disposition, the Idaho Supreme Court affirmed the district court. View "Hooley v. Idaho" on Justia Law

Erick Hall appealed the district court’s dismissal of his successive petition for post-conviction relief regarding his death sentence, which he received for the murder of Lynn Henneman in September 2000. Hall contended his appellate counsel had been ineffective for failing to raise certain claims related to the guilt and sentencing phases of his original trial in his first petition for post-conviction relief. Hall further asserted that the district court presiding over the original petition for post-conviction relief committed several reversible errors that appellate counsel failed to raise on appeal to the Idaho Supreme Court. The district court dismissed Hall’s successive petition in its entirety. Finding no reversible error in that decision, the Supreme Court affirmed. View "Hall v. State" on Justia Law

Darin Ogden appealed his conviction for possession of methamphetamine and drug paraphernalia. During a consensual encounter, officers searched Ogden’s vehicle outside of a business and arrested Ogden for felony possession. At trial, the State introduced redacted police officer on-body video showing the search. The nature and scope of the video became an issue during trial. The jury found Ogden guilty on both counts. At sentencing, Ogden objected to portions of a presentence investigation (PSI) report that included investigative and third-party records from two pending unrelated cases, and seven allegedly inaccurate statements in the PSI. Ogden’s objections to the PSI were largely denied. Ogden appealed to the Court of Appeals, which affirmed, and he then petitioned for review by the Idaho Supreme Court, arguing: (1) a response he gave to officers that was recorded on the video, but redacted, should have been admitted; and (2) it was error for the district court to permit irrelevant evidence to be presented to the jury. Given the accumulation of these alleged multiple errors, Ogden argued that his conviction had to be vacated. The Supreme Court determined district court erred by allowing the State to present evidence that the district court determined was not relevant, but that this error was harmless. "A single error does not require Ogden’s conviction to be vacated." Further, the Supreme Court found the district court abused its discretion in failing to redline the portions of the PSI it had agreed to correct, but did not abuse its discretion in declining to redline portions describing conduct Ogden was acquitted of. The case was remanded to district court to ensure that the victim’s medical records were stricken from the PSI. View "Idaho v. Ogden" on Justia Law

Officers from the Boise Police Department arrested Eduardo Plata Iniguez (“Plata”) outside his home for misdemeanor driving under the influence (“DUI”) without a warrant, and without witnessing the commission of the alleged crime. Upon his arrest, Plata was transported to jail where evidentiary breath testing was administered. At the jail, Plata failed to provide an adequate breath sample. Thereafter, officers procured a warrant from an on-call magistrate judge for a search of Plata’s blood, performed a blood draw at the Jail, and obtained an evidentiary sample of his blood. The State charged Plata with misdemeanor DUI (second offense), and Plata moved to suppress the blood draw evidence as a product of his unlawful arrest under Idaho v. Clarke, 446 P.3d 451 (2019). The Idaho Supreme Court concluded Plata made an initial showing of a causal nexus; Idaho’s exclusionary rule did not include a reasonable “mistake of law” exception; and the State did not argue another established exception applied (e.g., inevitable discovery or attenuation). Thus, the blood draw evidence should have been suppressed as derivative fruit of Plata’s illegal arrest, and the decision of the district court was reversed. View "Idaho v. Plata Iniguez" on Justia Law

Kirby Dorff appealed the denial of his motion to suppress evidence obtained after a police drug-sniffing dog jumped onto the exterior surface of his vehicle. Dorff argued the dog’s contact with his vehicle was a trespass, and therefore, an unlawful “search” under the common law trespassory test as articulated in United States v. Jones, 565 U.S. 400 (2012), applied in Idaho by Idaho v. Howard, 496 P.3d 865 (2021) and Idaho v. Randall, 496 P.3d 844 (2021). The Idaho Supreme Court found the drug dog intermeddled with Dorff’s vehicle when it jumped onto the driver side door and window, planted two of its paws, and sniffed the vehicle’s upper seams. Accordingly, law enforcement conducted a warrantless and unlawful “search” of Dorff’s vehicle by way of its drug dog. The denial of Dorff’s motion to suppress was reversed, his conviction was vacated, and this case was remanded to the district court for further proceedings. View "Idaho v. Dorff" on Justia Law

Following a jury trial, Travis Leavitt was convicted for statutory rape of a 17-year-old girl. He was 34 years old at the time of the incident. After the trial had begun, the State disclosed new evidence regarding Leavitt’s past criminal record, which the district court admitted. Leavitt challenged his conviction on the basis that the court allowed impermissible propensity evidence to be presented to the jury, including evidence of his criminal sexual history. Additionally, Leavitt asserted that even if the admission of such evidence were proper under Rule 404(b), the State failed to show good cause for its late disclosure of the evidence disclosed after trial began and evidence that he was a felon and a sex offender should have been barred as unfairly prejudicial under Rule 403. Leavitt’s appeal was initially heard by the Idaho Court of Appeals, which vacated his conviction and remanded the case for a new trial in an unpublished decision. The Idaho Supreme Court granted the State’s petition for review of the Court of Appeals’ decision. Though its reasoning differed, the Court reached the same result, concurring the trial court erred, and affirming the appeals court's outcome. View "Idaho v. Leavitt" on Justia Law

In April 2018, a teller working at CapEd Credit Union called the Boise Police Department to report a suspicious situation: a man came into the credit union, made a large cash deposit, exited the building, and then changed clothes in the parking lot. The man subsequently spoke with two other men in the parking lot. The teller reported that the men’s behavior made credit union employees nervous. Officers from the Boise Police Department responded to the credit union's call and detained one man in the parking lot. As the man in the parking lot was being detained, Officer Will Reimers arrived at the scene and proceeded into the credit union without speaking to the officers in the parking lot. As he waited for an employee to unlock the doors, Reimers observed two men, Patrick Maahs and Jordon Korona, standing at the teller counter. Reimers was dressed in full police uniform. One man left the counter and proceeded down a nearby hallway, then the other man followed. An employee informed Reimers that both men had gone into a bathroom, even though they were informed that it was a single person bathroom. Reimers took a position just behind a wall at the head of the hallway leading to the bathroom and called for backup. Once Maahs left the bathroom, he was subdued by police and eventually arrested on firearms and methamphetamine possession charges. Maahs moved to suppress the evidence seized from the search of his car on the basis that officers had conducted a de facto arrest and that his seizure was unsupported by probable cause or reasonable suspicion. The Idaho Supreme Court found the district court erred in denying the motion to suppress: Maahs was arrested without probable cause, and items found in his care should have been suppressed as "fruit of the poisonous tree." Maahs' judgment of conviction was vacated and the case remanded for further proceedings. View "Idaho v. Maahs" on Justia Law