Justia Constitutional Law Opinion Summaries

Defendant Christopher Flegel was indicted by a grand jury for lewd conduct with a child under sixteen in violation of Idaho Code section 18-1508. Defendant pled not guilty and was tried by a jury. The district court instructed the jury regarding the crime of Lewd Conduct and, as an included offense, the crime of sexual abuse of a child under sixteen years of age. The jury found Defendant not guilty of Lewd Conduct, but could not reach a verdict on the Sexual Abuse charge. Without resubmitting the matter to a grand jury, the State filed an amended indictment charging Defendant with Sexual Abuse. Defendant was tried by a jury on that charge and found guilty, to which he appealed. The appeal was initially heard by the Idaho Court of Appeals. It held that the indictment was properly amended because evidence admitted during Defendant's first trial supported the included offense of Sexual Abuse; and that the district court erred in failing to tailor the jury instruction on Sexual Abuse to eliminate the risk that the jury in the second trial would find Defendant guilty of conduct for which he was acquitted in the first trial. Because it concluded that such error was not harmless, the Court of Appeals vacated the judgment and remanded the case for a new trial. Upon review, the Supreme Court held that because the Sexual Abuse crime had not been submitted to the grand jury and was not an included offense of the crime of lewd conduct charged in the original indictment, the district court did not have subject matter jurisdiction. The Court therefore vacated the judgment and remanded the case with instructions to dismiss without prejudice.

In 2007, a mother walked in on her child and Defendant Jonathan Folk "just playing." She would later learn that Defendant had placed his mouth on the child's penis. The State charged Defendant with lewd conduct. Defendant would be later tried by a jury, found guilty and sentenced to life in prison without parole. Defendant appealed. Principal among his arguments was that the State violated his statutory right to a speedy trial. At issue for the Supreme Court's review was whether the postponement of trial at the defendant's request waived the protection of the speedy trial statute, even if the trial was rescheduled within the proscribed period. The Court found that Defendant's request indeed waives protection of the statute. However, the Court vacated Defendant's conviction on errors by the trial court. The Supreme Court remanded the case for a new trial.

The State appealed a district court's judgment granting Defendant Trevor Booth's petition for post conviction relief on the grounds that Defendant received ineffective assistance of counsel. In 2005, Defendant was accused of the shooting death of Leonard Kellum. Defendant was subsequently charged for first-degree murder. The State declined to seek the death penalty in this case. Defendant's attorney prepared a memorandum outlining his understanding of the potential penalties he would face. The attorney discussed the nuances of the statutory aggravating circumstances and the risks associated with taking the case to trial. Defendant then entered into a plea agreement with the State, agreeing to plead guilty first-degree murder. After a failed appeal challenging his sentence, Defendant filed for post-conviction relief. The court concluded that Defendant's attorney erroneously advised Defendant of the consequences of his plea agreement. The Supreme Court found that the district court did not err in concluding that Defendant's attorney was deficient, and that Defendant was prejudiced as a result. The Court affirmed the district court's decision to grant Defendant post-conviction relief.

In 2004, a jury found Petitioner Erick Hall guilty of first-degree murder, kidnapping and rape. Petitioner was sentenced to death. Petitioner appealed his conviction, and was appointed a public defender. In 2005, Petitioner petitioned the district court for post conviction relief. In that proceeding, the district court limited contact between Petitioner's counsel and the jurors that convicted him. Petitioner moved for reconsideration. In 2006, Petitioner moved to depose his trial attorneys and their investigator. The court allowed the deposition of trial counsel, but denied leave to depose the investigator. Petitioner's petition for post conviction relief was ultimately denied. On appeal to the Supreme Court, Petitioner challenged all of the district court's denials pertaining to the interview and deposition of jurors and key witnesses so that he could mount a successful appellate petition for relief. The Supreme Court found that the district court did not abuse its discretion in denying Petitioner's requests. The Court affirmed the district court's decision on all issues.

Defendant Jonathan Ellington appealed his conviction for murder and aggravated battery. He argued on appeal to the Supreme Court that prosecutorial misconduct, evidentiary errors, a biased jury and the "cumulative error doctrine" entitled him to a new trial. The Supreme Court found merit to several of Defendant's claims. The Court found that the district court abused its discretion when it denied Defendant a new trial after evidence came to light that the State's sole rebuttal witness provided false testimony at trial. The Court vacated Defendant's conviction and sentence, and remanded the case for a new trial.

Petitioner Zack Fields appealed the dismissal of his application for post conviction relief. In 1988, Petitioner was sentenced to death for the stabbing death of Mary Vanderford. Petitioner argued that he was wrongly accused and that DNA test results and affidavits of trial witnesses supported his argument. The district court ordered nineteen latent fingerprints from the murder scene to be run through the national fingerprint database and to have DNA testing of substances found on Petitioner and the victimâs clothing and underneath her fingernails. Testing determined that the fingerprints did not belong to Petitioner, nor did any of the substances contain his DNA. On appeal to the Supreme Court, Petitioner argued that he was entitled to an inference that the victim scratched her attacker because the attacker was close enough to stab her. With no DNA evidence of Petitioner recovered from the murder scene, Petitioner contended the district court erred by not viewing the DNA and fingerprint evidence âin a light most favorable toâ Petitioner. The Supreme Court found that there was ânothing but speculation supporting the claim that the scrapings from the victimâs fingernails came from her attacker. We therefore uphold the dismissal of [Petitionerâs] claim . . . because the DNA test results, in light of all admissible evidence, do not demonstrate that [Petitioner] is not the person who committed the murder.â