Justia Constitutional Law Opinion Summaries

In 2006, Woodrow John Grant pleaded guilty to aggravated battery; he successfully completed a period of retained jurisdiction and was placed on probation. In 2009, Grant was charged with possession of methamphetamine, domestic battery, aggravated assault, and unlawful possession of a firearm. Grant's appointed counsel moved to withdraw, stating that Grant had reneged on an agreed-upon plea bargain and that communications between them had broken down. The district court denied the motion. Later, Grant pled guilty to possession of a controlled substance and domestic battery, and admitted to violating the terms of his probation. The district court considered a letter and live testimony from the victim of Grant's domestic battery, in which the victim expressed her opinions on Grant's crime, character, and the sentence that would be proper for him. Thereafter, the district court sentenced Grant to five years fixed and five years indeterminate for domestic battery, to be served concurrently with a sentence of two years fixed and three years indeterminate for possession of methamphetamine. The district court revoked Grant's probation and executed his previously suspended sentence of four years fixed and six years indeterminate. The two new sentences were to be served consecutively to the reinstated 2006 sentence. Grant requested leniency in three I.C.R. 35 motions, which the district court denied. Grant appealed, arguing that the district court erred by refusing to allow his counsel to withdraw, by considering the victim's impact statements in their entirety, and by refusing his requests for leniency. Finding no error, the Supreme Court affirmed the district court in all respects. View "Idaho v. Grant" on Justia Law

Defendant challenged the trial court's decision to admit expert testimony regarding domestic violence and testimony of an excited utterance following his felony convictions of domestic violence and attempted strangulation. In addition, defendant challenged the deputy prosecutor's actions in soliciting testimony of the defendant's post-custody silence when accused of the crimes and the verdict finding defendant was a persistent violator. Upon review, the Supreme Court found no error and affirmed the district court's judgment. View "Idaho v. Parton" on Justia Law

A builder sued a homebuyer in a Utah state district court for failing to pay some charges for his home's construction; the homebuyer counterclaimed, alleging that the construction was defective. Shortly before the Utah state court rendered a judgment, the homebuyer sued the builder in an Idaho state district court, seeking to void the builder's allegedly fraudulent transfer of a ranch and appurtenant water shares in Franklin County, Idaho. The homebuyer also filed and recorded the Utah judgment in Franklin County, creating a lien on all of the builder's currently owned and after-acquired real property located there. The builder reversed the transfer, and therefore the ranch became subject to the lien. However, the homebuyer continued to prosecute the fraudulent-transfer action, and did not request a writ of execution. A few months later, the builder declared bankruptcy. In a settlement agreement, the bankruptcy trustee agreed to lift the automatic stay on the homebuyer's fraudulent-transfer action, and also abandoned the ranch from the bankruptcy estate. The homebuyer's judgment lien was not discharged in the builder's bankruptcy, but apparently all in personam causes of action were discharged. The fraudulent-transfer action was repeatedly delayed, and after five years from the entry of the Utah judgment, the homebuyer's lien expired. The homeowner had never attempted to renew the judgment, and had never requested a writ of execution from the Idaho district court. The builder then moved for summary judgment; the homebuyer filed a cross-motion for summary judgment, arguing that he was entitled to a writ of execution. The Idaho district court granted the builder's motion for summary judgment, denied the homebuyer's motion for summary judgment. Upon review, the Supreme Court concluded that the district court properly granted summary judgment in favor of the builder because no relief could be granted based on the expired lien, and because there was no timely request of a writ of execution for the Utah judgment. View "Grazer v. Jones" on Justia Law

This case arose from a traffic stop and subsequent arrest of Defendant Phillip James Morgan. A Boise City police officer observed Morgan driving in a way that caused the officer to believe Defendant was trying to avoid him. The officer stopped Defendant after observing that Defendant's vehicle did not have a front license plate. Defendant was subsequently arrested for DUI. He filed a motion to suppress all evidence garnered from the traffic stop, arguing the officer did not have reasonable suspicion to initiate the stop. The district court concluded that although Defendant may not have actually violated traffic laws, the officer had reasonable articulable suspicion to believe that he had done so. Defendant's motion to suppress was denied, and he was convicted of felony DUI after a jury trial. Defendant appealed. Upon review, the Supreme Court reversed, concluding the officer lacked the reasonable, articulable suspicion necessary to justify the traffic stop. The judgment of conviction was vacated and the case remanded for further proceedings. View "Idaho v. Morgan" on Justia Law

Defendant Daniel Straub pled guilty to vehicular manslaughter, and as part of his plea, agreed to pay restitution to his victims. After a hearing, the district court determined that Defendant owed $554,506.67 to the decedent's family, primarily for future medical insurance premiums and for five years of lost wages. Defendant appealed the restitution order, arguing that the court unreasonably or illegally interpreted the restitution statutes. Finding that Defendant did not waive his right to appeal the district court's order in his plea agreement, and that the district court abused its discretion in ordering Defendant to pay restitution for the victim's future lost wages, the Supreme Court reversed the order and remanded the case for further proceedings. View "Idaho v. Straub" on Justia Law

Defendant-Appellant Randy McKinney was sentenced to death for first-degree murder, and received sentences for conspiracy to commit murder, robbery, and conspiracy to commit robbery. His death sentence was set aside in a federal habeas proceeding. Defendant and the State reached a sentencing agreement with regard to the murder charge for which he received a fixed life term without possibility of parole to be served concurrently with his other sentences. On appeal, Defendant alleged that he was illegally sentenced, violating the double jeopardy clause of both the state and federal constitutions, as well as Idaho's multiple-punishment statute (repealed in 1995). Upon review, the Supreme Court found no error in Defendant's sentences and affirmed them. View "Idaho v. McKinney" on Justia Law

Defendant Abraham Scraggins appealed two district court orders revoking his probation. Defendant was convicted of sexual battery of a minor in 1993, which required that he register as a sex offender in Idaho. In 2009, the State charged him with failure to register when he moved to Ada County in 2008. Defendant pled guilty and received a unified sentence of ten years, five of which were fixed. The sentence was suspended, and Defendant was placed on probation. Under the terms of his probation, Defendant was to serve time in jail at his probation officer's discretion without prior approval of the court. A month after sentencing, the State moved to revoke Defendant's probation, alleging he violated the terms of probation by drinking alcohol and failing to stay at his registered address for a nine-day period. Later in 2009, the State charged Defendant again with failing to register as a sex offender. In a plea agreement, Defendant admitted to violating the terms of his first probation, and pled guilty to failing to register in the second case. The district court revoked Defendant's probation in the first case, and imposed a unified ten-year sentence, with five and one-half years fixed. Less than two months later, probation officers performing a "residence check" found Defendant had contacted his victim, and that he had consumed alcohol. In lieu of filing a report of violation of his probation, Defendant served ten days of the discretionary jail time previously authorized by the district court. At a disposition hearing, Defendant objected to the district court revoking his probation based on these last violations. He argued that because he "had been punished already for this exact same conduct" by serving discretionary jail time, and because "there [was] no new conduct that he has been found in violation for," that a revocation of probation would be a violation of his due process rights. The district court rejected this argument, and accordingly revoked his probation in both cases. It then ordered that the sentences in both cases be executed. Defendant appealed to the Supreme Court, which consolidated the cases on appeal. Upon review, the Court concluded that nothing the probation officers or district court did "affected any articulable due process right." Accordingly, the Court affirmed the district court's decision to revoke Defendant's probation. View "Idaho v. Scraggins, Jr." on Justia Law

Defendant Todd Sunrier is the father of twin girls who, in December 2008, were about three and one-half years old. One of the daughters mentioned to her aunt that Defendant had "hurt her 'business,'" a term she had been taught to use when referring to her vagina. Law enforcement was contacted; Defendant ultimately admitted that for a year he had been abusing both daughters. Defendant was then charged with two counts of lewd conduct. He pled not guilty and was tried before a jury. The jury found Defendant guilty, and he was sentenced to twenty-five years in the custody of the Idaho Board of Correction, with five years determinate and the remaining twenty indeterminate, concurrent sentences. Defendant appealed when the trial court declined to place him on probation. The appellate court reversed the conviction on the ground that there was no evidence corroborating Defendant's confessions as required by the corpus delicti rule. The State filed a petition for review which the Supreme Court granted. Upon review, the Supreme Court found the corroboration was sufficient and affirmed the judgment of conviction. The Court also overruled its prior decisions adopting the corpus delicti rule. View "Idaho v. Suriner" on Justia Law

In 2009, the State filed a petition against John Doe, charging that he was within the purview of Idaho's Juvenile Corrections Act (JCA) for delivery of a schedule III controlled substance, hydrocodone. The State and Doe's counsel reached an agreement whereby Doe admitted to the charge and, in exchange, the State waived proceedings to bring Doe into adult court. At the conclusion of Doe's sentencing hearing, the magistrate judge memorialized his ruling in a "decree" that was issued that same day. The decree stated, "It is hereby Ordered, Adjudged and Decreed that [Doe] is within the purview of the [JCA] and shall be placed on Formal Probation supervision not to exceed 2 years." In the first year of Doe's probation, he had two probation review hearings, both of which demonstrated good behavior. At Doe's one-year probation review hearing, Doe's counsel argued that the magistrate should convert his formal probation to an informal adjustment. Doe's counsel could not cite any authority for converting the sentence, but believed that the court had broad authority to do so based on the interests of justice. The State objected and argued that the court did not have authority to convert the formal probation to an informal adjustment. Ultimately, the magistrate court stated that it had the authority to convert the sentence and entered a "supplemental decree nunc pro tunc to date of original order," granting Doe an informal adjustment and dismissing the case. The magistrate then issued an Order Supplementing Decree that provided "Formal Probation converted to Informal Adjustment, nunc pro tunc 05/05/09." The State filed an appeal to the district court. The district court affirmed the magistrate court's order. The State timely appealed to the Supreme Court. Because it was improper for the magistrate to convert Doe's sentence, any subsequent dismissal or termination of the improperly substituted informal adjustment could not be upheld. The Supreme Court reversed the district court's order and remanded the case for reinstatement of the 2009 decree. View "Idaho v. Doe (2012-09)" on Justia Law

This case arose out of an appeal of the district court's refusal to grant a dismissal following an evidentiary hearing in 2011. In 1988, Defendant Philip Dieter entered a plea agreement with the State in which he agreed to plead guilty to lewd conduct in exchange for the State's dismissal of two related charges. Subsequently, the court entered an Order of Withheld Judgment and Order of Probation. Following an amended order that enlarged the terms of probation, the district court dissolved and terminated probation in 1992. However, it did not dismiss the case. Defendant argued that the district court should have been required to dismiss the case because the initial order contained a clause that stated the case would be dismissed if Defendant fully complied with his probation terms. He also argued that the district court had no authority to deny the dismissal. Upon review of the district court's decision, the Supreme Court affirmed.