Justia Constitutional Law Opinion Summaries

Jeffrey Murray appealed the district court's order dismissing his petition for post-conviction relief after he pled guilty to felony domestic violence and was sentenced to three years fixed followed by seven years indeterminate. Murray's petition for post-conviction relief argued, among other things, that he received ineffective assistance of trial counsel. Upon review, the Supreme Court affirmed the district court's dismissal of Murray's petition for post-conviction relief: "although Murray has provided argument that his counsel was deficient in failing to inform him of his ability to obtain a confidential domestic violence evaluation prior to pleading guilty, he has not provided a single authority or legal proposition to support his argument. Murray merely states, without support, that his counsel’s failure to advise him of his ability to undergo a confidential evaluation 'represented deficient performance.'" View "Murray v. Idaho" on Justia Law

Robert Hansen pled guilty to the charges of aggravated driving under the influence and leaving the scene of an injury accident. At the sentencing hearing the district court allowed the victim's father to give an informal statement over Hansen's objection that the father was not a victim entitled to make a victim impact statement. The district court sentenced Hansen to a total of 15 years imprisonment for the two convictions. Hansen appealed. The Court of Appeals determined that it was error for the district court to allow the father’s statement, because the father was not a victim. However, the Court of Appeals held that any error was harmless. Hansen also appealed his sentences on both the aggravated driving under the influence charge and the leaving the scene of an injury accident charge, maintaining that the district court's departure from the plea agreement on one charge opened up both for review. The State petitioned this Court for review of whether the district court erroneously admitted the father’s statement. Upon review, the Supreme Court concluded the district court did nor err by admitting the victim's father's statement at the sentencing hearing, and it affirmed with regard to Hansen's sentence. View "Idaho v. Hansen" on Justia Law

Defendant Alisha Murphy was convicted in 2001 of first degree murder of her husband, James. She appealed the conviction and sentence, which were affirmed in an unpublished opinion. Defendant filed a pro se application for post-conviction relief asserting numerous claims of ineffective assistance of counsel, police misconduct, prosecutorial misconduct, and judicial misconduct, together with a motion for the appointment of counsel. The Court of Appeals concluded defendant had made a successive petition for post-conviction relief and denied it. On appeal, defendant argued that the district court erred in denying her request for counsel, summarily dismissing her successive petition, and denying her I.R.C.P. 60(b) motion for reconsideration. She argued that her ineffective assistance of trial counsel claims were properly before the district court on successive petition because, under the Supreme Court’s decision in "Palmer v. Dermitt," (635 P.2d 955 (1981)), ineffective assistance of post-conviction counsel constituted sufficient reason to bring a successive petition under I.C. 19-4908. The Court of Appeals reversed in part and affirmed in part, concluding that the district court properly dismissed three out of the four ineffective assistance of counsel claims without appointing counsel. As to the remaining claim, the Court of Appeals held that defendant alleged sufficient facts to raise the possibility of a valid claim and remanded that claim to the district court for appointment of counsel. Defendant argued to the Supreme Court that she was entitled to relief from the district court’s orders denying counsel and summarily dismissing each of the claims in her successive petition. Upon review, the Supreme Court concluded that that ineffective assistance of post-conviction counsel was not a sufficient reason under I.C. 19-4908 for allowing a successive petition, and thus, overruled Palmer v. Dermitt. Accordingly, the Court of Appeals’ decision was reversed and the district court’s order of summary dismissal of defendant's successive petition for post-conviction relief was reinstated. View "Murphy v. Idaho" on Justia Law

Defendant-appellant Samuel Glenn appeals the district court’s denial of his motion to dismiss a 2010 driving under the influence (DUI) charge. The State sought an enhanced sentence based upon a 2001 DUI conviction. The district court had previously dismissed that 2001 DUI conviction. Defendant argued on appeal that the district court erred because Idaho Supreme Court precedent holds that cases dismissed pursuant to I.C. 19-2604 are a nullity and cannot later be used as sentencing enhancements. The State contended that the district court erred in considering the merits of Defendant's untimely motion to dismiss and that precedent allowed an enhanced sentence based on a previously dismissed DUI conviction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Glenn" on Justia Law

Alan and Diane Johnson were shot and killed in their home. The Johnsons' sixteen-year-old daughter Sarah was home at the time of the shooting. She consistently denied any involvement, but gave several different accounts of what she was doing, what she saw, and what she heard prior to and after the murders. After a lengthy trial, a jury found Johnson guilty of first-degree murder of her parents. The district court sentenced Johnson to concurrent life sentences, plus fifteen years for a firearm enhancement. Finding no reversible error, the Supreme Court affirmed her conviction and sentence. View "Johnson v. Idaho" on Justia Law

Defendant-Appellant David Lee appealed the district court's order that denied his motion to strike certain language from his acquittal. In that judgment, the court declared that because defendant was "a serious pedophile, it is hoped that the authorities will be able to keep a closer watch on him in the future." Upon review, the Supreme Court concluded that the "surplus" language should not have been included in the judgment of acquittal in the first place when defendant raised the issue in his motion. That motion should have been granted. Therefore, the Supreme Court reversed the district court's denial of the motion to strike, and the case remanded for entry of an amended judgment eliminating the sentence in question. View "Idaho v. Lee" on Justia Law

Petitioner Erick Hall was convicted and sentenced to death twice: first for kidnapping, murder and rape; second for rape and murder. While Hall's petition for post-conviction relief was pending for his first sentence, his second trial for rape and murder was underway. During the overlap of Hall I and Hall II, there were numerous communications between Hall's trial attorneys representing him in Hall II, and the State Appellate Public Defender's (SAPD) office, handling Hall's post-conviction proceedings in Hall I. It was the communications between Hall's trial counsel that were the basis for a potential conflict of interest in this case, given that the issue before the Supreme Court in this appeal was ineffective assistance of trial counsel in his second petition for post-conviction relief. In 2008, Hall filed a petition for post-conviction relief in connection with his Hall II conviction. Two years later, the SAPD filed an Ex Parte Notice of Possible Conflict of Interest with the district court. The Ex Parte Notice stated that the SAPD had "cooperated with trial counsel in Hall II by sharing testing and expert information obtained in Hall I." Dennis Benjamin [. . .] agreed to evaluate the conflict and advise Mr. Hall whether or not the conflict should be waived." With no knowledge of the Ex Parte Notice, the State filed a Motion for Inquiry into Possible SAPD Conflict. Although Benjamin conducted an extensive inquiry into whether the SAPD was conflicted, the district court did not question Benjamin about his findings. Rather, the court believed that Benjamin was too closely aligned with the SAPD to be truly independent. The court then issued a Memorandum Decision and Order Appointing Keith Roark as Independent Counsel. The SAPD filed a Motion to Reconsider Memorandum Decision, which the court denied. On appeal, Hall acknowledged the trial court had an affirmative duty to inquire into a potential conflict whenever it knew or reasonably should have known that a particular conflict may exist. However, Hall argued that the cases relied on by the district court in finding that it had an affirmative duty to conduct a thorough and searching inquiry were distinguishable because the possibility of a conflict in this case was raised by Hall's counsel, not Hall himself. Additionally, Hall contended that Roark's conflict inquiry was unnecessary and duplicative because: (1) Benjamin assessed the possible conflict and concluded no conflict existed; and, (2) Benjamin made his conclusion after reviewing all relevant information. Further, Hall argued that the district court's second inquiry was unnecessary because the conduct of Hall's previous attorneys at the SAPD's office should not have been imputed to Hall's then-current post-conviction counsel. After its review, the Supreme Court concluded the district court erred in appointing Roark as independent counsel; the district court order granting Roark access to the SAPD's client file violated Hall's attorney-client privilege. Therefore the Supreme Court vacated the district court's order appointing Roark as independent conflict counsel and its order requiring the SAPD to pay for Roark's services. View "Hall v. Idaho" on Justia Law

In 1991, appellant Zane Fields was sentenced to death for first degree murder. In 2011, appellant filed his sixth successive petition for post-conviction relief. He raised claims of actual innocence, prosecutorial misconduct, and violations of the right to counsel, due process, and the right to a fair trial. The district court granted the State's motion to dismiss appellant's petition because his claims were barred by I.C. 19-2719(5). Appellant appealed the district court's dismissal of his petition. Finding no reversible error, the Supreme Court affirmed. View "Fields v. Idaho" on Justia Law

The issue on appeal before the Supreme Court in this case arose from an order denying an employer's motion to have a laptop returned that had been seized from its employee during a search conducted at the employee's home by a probation officer. The Court affirmed the order denying the return of the laptop, but held that the laptop could not be searched without a search warrant issued upon a judicial finding of probable cause. View "Idaho v. Ruck" on Justia Law

The issue on appeal before the Supreme Court arose from a district court order that denied Defendant's motion to dismiss for the lack of probable cause, a felony charge of possession of methadone. The methadone was discovered upon the birth of the defendant's baby girl in the umbilical cord. Upon review of the matter, the Supreme Court held that for the purposes of determining whether there was probable cause to believe that the defendant had possessed a controlled substance, the magistrate judge could reasonably have inferred that the defendant consumed the methadone; that she possessed it before she consumed it; and that she knew it was either methadone or a controlled substance when she was possessing it. View "Idaho v. Neal" on Justia Law