Justia Constitutional Law Opinion Summaries

Defendant-Appellant Robert Gurney pled guilty to possession of marijuana with intent to deliver. He then successfully completed drug court. Upon completion, he requested and received a dismissal of the charge. He also requested that the record of his criminal case be sealed, pursuant to I.C.A.R 32(i), on the basis of economic hardship. The district court denied this second request. It subsequently denied Defendant's request to change the caption of this case on appeal to an abbreviated version of his name which would conceal his identity. Defendant appealed both decisions. Upon review, the Supreme Court concluded the district court did not err by denying Defendant's motion to seal his records or amend the caption of his case: "[a]s the district court recognized that the decision was committed to its discretion, recognized and applied the applicable legal standard, and did so through the exercise of reason, [the Court was] unable to conclude that the decision was an abuse of discretion."

Defendant-Appellant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. Defendant raised several issues on appeal pertaining to the sufficiency of the evidence presented against him at trial, and procedural errors that prejudicially lead to his conviction. Taking each of Defendant's issues raised on appeal, and after a review of the trial record and applicable law, the Supreme Court found that the jury was presented with sufficient evidence from which it could reasonably find that Defendant was guilty of first-degree murder, and that the trial court committed no fundamental errors that adversely impacted Defendant's trial. Accordingly, the Court affirmed Defendant's convictions and sentences.

Defendant-Appellant Daniel Johnson petitioned the district court for an exemption from sex offender registration requirements. The district court determined that the 2009 amendments to the Idaho Sexual Offender Registration Notification and Community Right-to-Know Act (SORA) precluded such exemption and therefore denied his petition. On appeal, Defendant argued that the district court’s application of SORA was unconstitutional. Because Defendant filed his petition in his already-dismissed criminal case, the Supreme Court concluded the district court lacked jurisdiction to consider the matter. The Court therefore vacated the district court’s decision.

Defendant John Joseph Delling appealed his conviction based on his conditional pleas of guilty to two counts of second-degree murder. Defendant was initially charged with two counts of first-degree murder for the deaths of David Boss and Brad Morse. These counts were later amended to second-degree murder. Shortly after being charged, Defendant's counsel motioned for a mental health evaluation to determine whether Defendant was fit to proceed and able to aid in his own defense. Defendant requested that the Supreme Court reconsider and overrule its decision in "State v. Searcy" (798 P.2d 914 (1990)), to find that Idaho's abolition of the insanity defense was unconstitutional. Defendant also asserted that the district court abused its discretion and imposed excessive sentences. Upon careful review of the applicable legal authority and the arguments presented in Defendant's appellate brief, the Supreme Court concluded Defendant had not provided any argument that showed the precedential cases to be wrongly decided, unwise, or unjust. By looking at each argument individually, none of Defendant's constitutional rights were infringed by the abolition of the insanity defense. Furthermore, the Court also found that the sentence imposed by the district court was reasonable and not an abuse of discretion.

Defendant John Schulz appealed his conviction of felony domestic battery and the attempted strangulation of his fifteen-year-old daughter. Both charges required the state to prove that the daughter was Defendant's "household member" as defined by the applicable statute. The district court granted Defendant's motion to dismiss based on the fact that she did not fall within that definition. Because the Supreme Court found that the definition of "household member" plainly limited the application to "intimate partners" and thus, did not extend to a child living with her father, the Court affirmed.

Defendant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. In 2007, a jury convicted him for the stabbing death of Cassie Jo Stoddart. Defendant raised multiple issues on appeal, among them, he challenged the sufficiency of the evidence presented at trial. Furthermore, Defendant alleged multiple errors at trial prejudiced him from receiving a fair trial. Upon careful review of the trial court record, the Supreme Court found that the jury was provided with sufficient evidence from which it could reasonably find beyond a reasonable doubt that Defendant was guilty of first-degree murder, and that the trial court did not err in its rulings at trial. Accordingly, the Court affirmed Defendant's convictions and sentences.

This appeal arose from Defendant Dean Clay Miller, Jr.'s conviction for burglary, assault with intent to commit robbery, possession of methamphetamine, and being a persistent violator. The Supreme Court reduced this case to two issues: (1) whether a persistent violator enhancement must be alleged in the information to give a court subject matter jurisdiction; and (2) whether Defendant's sentence was excessive and constituted an abuse of discretion. Defendant pled guilty to to the charges against him, but on appeal argued that the district court lacked subject matter jurisdiction because the State did not allege the persistent violator enhancement in the information. He also argued that if the court did have subject matter jurisdiction, the sentence was excessive in light of his mental health condition and other mitigating factors. Upon review, the Supreme Court held that the district court had subject matter jurisdiction to sentence Defendant, and did not abuse its discretion when it sentenced him.

Defendant Ora Carson was convicted of the murder of his three-month-old son and was sentenced to a fixed life sentence based upon the jury’s finding that he exhibited utter disregard for human life. On appeal, he challenged the trial court’s ruling barring impeachment evidence of the child’s mother, statements made by the prosecuting attorney during closing argument, and the jury instruction defining “utter disregard.” Upon review, the Supreme Court found that Defendant’s trial counsel did not object to the challenged comments: "[b]y the challenged comments, the prosecutor was not expressing a personal opinion regarding the credibility of Mother. Defendant had testified that Mother killed Baby. The prosecutor was merely arguing that Mother’s conduct, as shown by the evidence, was inconsistent with that allegation. The prosecutor and defense counsel are free to argue the evidence and the reasonable inferences that can be drawn from that evidence, even if the evidence argued indicates that a witness is or is not truthful." With regard to the jury instructions given by the trial court, the Supreme Court concluded that Defendant did not present "any logical argument" that the jury would not have understood the meaning of "utter disregard." Accordingly, the Court affirmed the trial court's judgment.

Cassie Jo Stoddart was murdered in 2006. Defendant Brian Draper, who was sixteen years-old at the time of Stoddartâs murder, and Torey Adamcik, also a juvenile, were arrested and charged with murder and conspiracy to commit murder. Both were tried as adults, and convicted during separate trials. Defendant was sentenced to a term of fixed life imprisonment for the murder charge and a life sentence with thirty years fixed for the conspiracy charge. Defendant raised seven issues on appeal: 1) the jury instructions for both murder and conspiracy relieved the State of proving all elements of the crimes and violated his right to due process of law; 2) his fourth police interview should have been suppressed as his parents were not present at the interview; 3) the jury instructions and the district courtâs failure to suppress the interview, even if individually harmless, cumulatively constitute reversible error; 4) the sentences should be vacated because the investigatorâs presentence report was biased; 5) Defendant's fixed life sentence for murder violated the Idaho and U.S. Constitutionsâ prohibition of cruel and unusual punishment; 6) the district courtâs sentences constituted an abuse of discretion; and 7) the district courtâs denial of Defendant's motion under Idaho Criminal Rule 35 to modify his sentences constituted an abuse of discretion. Upon review of the trial court's record, the Supreme Court only found error in the jury instruction pertaining to Defendant's conspiracy charge, but affirmed the trial court in all other respects. The Court vacated Defendant's conviction on conspiracy to commit first degree murder and remanded the case for a new trial on that charge.

This case arose from Defendant Diego Morales Peregrinaâs conviction on two counts of aggravated battery and two firearm enhancements; one for each battery. Peregrina argued on appeal of his sentence that there was insufficient evidence to support the district courtâs "implicit" finding that the crimes arose out of divisible courses of conduct, and that even if there was, the State had the burden to submit the issue of divisibility to the jury and prove it beyond a reasonable doubt. Upon review of the trial court record, the Supreme Court found that no instruction was requested by either Peregrina or the State regarding I.C. 19-2520E, which states that when two crimes "arise out of the same indivisible course of conduct," the defendant "may only be subject to one (1) enhanced penalty." The district court sentenced Peregrina as follows: ten years fixed for the first count of aggravated battery; ten years fixed for the second count of aggravated battery consecutive to the first count; ten years indeterminate enhancing the sentence in the first count; and ten years indeterminate enhancing the sentence in the second count, both consecutive to the previous counts. Peregrina was also sentenced to five years fixed for his conviction for unlawful possession of a firearm, to run concurrent with the other sentences, with credit for two hundred days served. The Supreme Court found that the State's failure to submit the issue of divisibility to the jury and to prove it beyond a reasonable doubt. The Court remanded the case back to the district court for further proceedings.