Justia Constitutional Law Opinion Summaries

Kathryn Adkins appealed her conviction for felony concealment of evidence. Whether the crime of concealment of evidence was a felony depends on whether the investigation or trial to which the evidence related involved a misdemeanor offense or a felony offense. Because the felony status of the underlying offense was a “fact” that increases the maximum sentence that may be imposed, Adkins argued that in a jury trial this must be decided by the jury, not the judge. To this the Idaho Supreme Court disagreed and affirmed the judgment of conviction. The sentence imposed by the district court, however, exceeded the maximum permitted under Idaho Code section 18-2603. The sentence was vacated and remanded for entry of a corrected sentence. View "Idaho v. Adkins" on Justia Law

Darin Ogden was convicted on one count of sexual exploitation of a child and one count of sexual battery. Ogden argued the convictions should have been vacated because of several erroneous evidentiary rulings made by the district court, which deprived Ogden of his constitutional right to confront witnesses and present a defense. Alternatively, Ogden argued his sentences should have been vacated because the court considered unreliable information related to earlier conduct for which he had been acquitted. Ogden also requested that the presentence investigation report be redacted to omit those allegations. The Idaho Supreme Court determined that although the district court did not abuse its discretion by denying Ogden’s first Rule 412(b) motion seeking to introduce evidence of V.H.’s (the victim) sexual history with Michael Roller, it abused its discretion by denying Ogden’s second Rule 412(b) motion seeking to introduce evidence of V.H.’s sexual history with Ty Birchfield. The Court affirmed Ogden's conviction for sexual battery, but vacated his conviction for sexual exploitation of a child, and the case was remanded for a new trial. View "Idaho v. Ogden" on Justia Law

Police apprehended defendant Clarence Lancaster for questioning relating to several ATM thefts in Boise, Idaho. He was later charged and ultimately entered conditional guilty pleas to two felonies: burglary and grand theft. This appeal arose from the denial of his motion to suppress. Lancaster argued that his confession and other evidence should have been suppressed because the arresting officers violated Idaho Code section 19-608 by failing to tell Lancaster the basis of his arrest. He maintains that this statutory violation rendered his arrest an unreasonable seizure under Article 1, Section 17 of the Idaho Constitution. He also argues that the district judge abused its discretion at sentencing by failing to strike an attachment to the Presentence Investigation Report. Finding no reversible error, the Idaho Supreme Court affirmed Lancaster's conviction. View "Idaho v. Lancaster" on Justia Law

On April 24, 2019, Deputy Brott stopped defendant-appellant Arthur Vivian’s car because Vivian’s brake lights were not working. Brott recorded the stop using a body camera. Vivian informed Brott that his license had been suspended and Brott began investigating the reason for Vivian’s suspended license. After five minutes and forty seconds of interaction with Vivian, Brott returned to his vehicle to run Vivian’s license. Brott talked to Officer Short, who had recently arrived at the scene. Short advised Brott that there was a possibility there could be narcotics in Vivian’s vehicle. Brott called for a drug detecting K-9 unit nine minutes into the stop. Brott exited his patrol car with the completed citation and Vivian’s license at sixteen minutes and forty-six seconds into the stop. Deputy Hickam and a drug detecting K-9 arrived eighteen minutes and thirty-seven seconds into the stop. At nineteen minutes and twenty-nine seconds Brott approached Vivian’s vehicle, asked Vivian to exit the vehicle and requested to pat him down. Brott issued the suspended license citation at twenty minutes and forty seconds. During the time Brott explained the citation to Vivian, the drug K-9 alerted to a controlled substance in the vehicle. A subsequent search discovered a bag containing methamphetamine. Vivian appealed the district court’s denial of his motion to suppress evidence obtained following his traffic stop, arguing the stop was unlawfully extended, and statements made before and after the delay were gathered in violation of his Fourth Amendment rights. The State contended that evidence of the drugs would have been inevitably discovered, and thus statements made relating to those drugs were admissible under the same doctrine. The Idaho Supreme Court rejected that argument, finding verbal statements were different than physical evidence "because a defendant could choose, if given time for reflection, not to make the statements or to answer differently." The Court held the inevitable discovery exception did not apply to statements that would otherwise be excluded as “fruit of the poisonous tree.” The district court’s decision that Vivian’s post-Miranda statements were admissible was reversed, Vivian’s judgment of conviction was vacated, and the case was remanded for further proceedings. View "Idaho v. Vivian" on Justia Law

Probation officers detained Natalie Miramontes while conducting a residence check on a female probationer, Christine Evans. During the detention, probation officers searched Miramontes’ purse and found suspected drug paraphernalia. Probation officers paused the search and contacted police. Once police arrived, officers resumed the search and, inside a pantry converted to a spare bedroom, they uncovered more drug paraphernalia and a substance that tested presumptively positive for methamphetamine. Miramontes told police she had been sleeping inside the spare room. Miramontes moved to suppress all evidence found during her detention. The district court denied her motion. Miramontes entered a conditional guilty plea and reserved her right to appeal. She appealed, and the Court of Appeals affirmed her conviction. Miramontes petitioned the Idaho Supreme Court for review, arguing the district court erred when it denied her motion to suppress because officers searched her purse without reasonable and articulable suspicion. She also argued the items found during the later search of the spare bedroom would not have been inevitably discovered without the unlawful search of her purse. The Supreme Court reversed the district court’s decision denying Miramontes’ motion to suppress and remanded for fact-finding on whether Miramontes was unlawfully searched. View "Idaho v. Miramontes" on Justia Law

Matthew Fox appealed his convictions for robbery, aggravated battery, possession of marijuana, and possession of methamphetamine. Charges arose from an incident in 2017 in which Fox allegedly pistol whipped his victim demanding money allegedly owed for methamphetamine. The victim drove to a nearby school's parking lot, "hysterically trying to get someone to call 911." A parent leaving his child's concert at the school noticed the victim and called 911. Officers responding to the victim used his description of the incident to find Fox's car and arrest Fox. The search netted (1) a briefcase with methamphetamine, marijuana, and other drug paraphernalia, (2) the victim's cellphone, and (3) a Smith & Wesson handgun. The same day as Fox’s arrest, Fox’s former fiancé, Nicole Walker, called the Kootenai County Sheriff’s department to report that her 9mm handgun was missing. Walker went into the police station the next day and identified the Smith & Wesson handgun found in Fox’s car as hers. Finding no reversible error in the trial court's decision, the Idaho Supreme Court affirmed Fox's convictions and sentences. View "Idaho v. Fox" on Justia Law

Michanglo Smith challenges multiple evidentiary decisions of the district court involving two jury trials. The underlying convictions stem from a violent incident involving Smith and his then girlfriend (“Girlfriend”) on the night of January 27, 2018 and lasted into the morning of January 28, 2018. According to Smith, Girlfriend was attacked by some other person(s) to whom she owed money. In contrast, Girlfriend testified that Smith had attacked, threatened, and attempted to strangle her repeatedly—not some other person(s). In the first trial, after hearing from both Girlfriend and Smith, in addition to multiple witnesses corroborating Girlfriend’s injuries and reported version of events, the jury convicted Smith on all counts except the attempted strangulation charge. The jury was unable to reach a decision on the attempted strangulation charge. The State re-tried Smith on that charge, and after a second trial, a jury found him guilty of attempted strangulation. Smith appealed his convictions and the subsequent restitution order. Finding no reversible error, the Idaho Supreme Court affirmed Smith's convictions. View "Idaho v. Smith" on Justia Law

In August 2020, police interviewed Dr. Daniel Lee Moore (“Moore”) concerning the murder of Dr. Brian Drake (“Drake”), who had been shot in his chiropractic office over five months earlier. Though Moore invoked his right to an attorney at least three times, the interrogation continued. Moore eventually confessed to the crime and was charged with second-degree murder. Following a defense motion, the district court suppressed the confession after finding that Moore’s Miranda rights had been violated. The district court later dismissed the case, concluding that because the State had relied on the tainted confession in the preliminary hearing, there was insufficient evidence to support a showing of probable cause. The State appealed the dismissal, conceding that there was a Miranda violation, but arguing the district court erred in dismissing the case. Although the Miranda violation rendered Moore’s statements inadmissible in the State’s case-in-chief, the State maintains that the statements could still be used to impeach a claim of innocence by Moore if he were to testify at trial. After review, the Idaho Supreme Court affirmed in part and reversed in part. The Court affirmed the ruling that the confession was inadmissible in the State's case-in-chief, but reversed the ruling that the confession would also be admissible for impeachment purposes, should Moore testify at a future preliminary hearing or at trial. The Supreme Court affirmed the district court’s decision granting the motion to dismiss pursuant to Idaho Code section 19-815A. The rulings in this opinion as to the limited admissibility of Moore’s confession would govern any future prosecution of Moore related to the murder of Drake. View "Idaho v. Moore" on Justia Law

After a jury found Jesus Garcia guilty on charges related to a deadly night-club incident, the district court ordered restitution against Garcia in the amount of $162,285.27. In Idaho v. Garcia, 462 P.3d 1125 (2020) (“Garcia I”), the Idaho Supreme Court reversed the district court’s restitution order after determining the district court had not properly considered Garcia’s future ability to repay that amount. On remand, the district court held a second restitution hearing, weighed evidence from before and after remand, and determined Garcia had the foreseeable ability to pay the restitution amount. The district court then reinstated the original order in full. Garcia appealed, arguing the district court’s decision ignored the Supreme Court’s restitution holding in Garcia I, and was not supported by substantial evidence. Finding no reversible error, the Supreme Court affirmed the trial court. View "Idaho v. Garcia" on Justia Law

Gerald Pizzuto, Jr., was convicted of two brutal murders and sentenced to death in 1986. After the Idaho Commission of Pardons and Parole voted 4-3 to recommend that Pizzuto’s death sentence be commuted to life without the possibility of parole, Idaho Governor Brad Little rejected the recommendation, thereby allowing Pizzuto’s death sentence to remain in effect. Pizzuto challenged the Governor’s action by filing an Idaho Criminal Rule 35(a) motion to correct his sentence, and a sixth petition for post-conviction relief. The district court granted both Pizzuto’s motion and petition after finding Idaho Code section 20-1016 was unconstitutional. The State appealed to the Idaho Supreme Court. Finding Idaho Code section 20-1016 was a constitutional expression of the authority granted to the Legislature, the Supreme Court determined the district court erred in granting both Pizzuto’s Rule 35(a) motion and his petition for post-conviction relief. “Both decisions were based on the erroneous grounds that Governor Little lacked authority to reject the Commission’s clemency recommendation because Idaho Code section 20-1016 is unconstitutional. … Because the 1986 amendment to Article IV, section 7, authorizes the legislature to govern the Commission’s commutation powers ‘by statute,’ and Idaho Code section 20-1016 is a proper expression of that authority, we reverse the district court’s orders and remand Pizzuto’s cases for further proceedings.” View "Idaho v. Pizzuto" on Justia Law