Jesse R. Walters

This case concerned whether evidence obtained by a city police officer during a traffic stop outside his jurisdiction should be suppressed in a prosecution for driving under the influence and driving without privileges. The magistrate granted the defendant's suppression motion, finding the officer was merely following rather than in fresh pursuit because he did not activate lights until one mile beyond city limits, and the district court affirmed. The Court of Appeals reversed, holding that the stop qualified as fresh pursuit under Idaho Code § 19-705 where the officer observed a speeding violation inside the city, followed the vehicle to make a stop as soon as possible, and activated lights at the first safe opportunity without unreasonable delay. The court reasoned that an officer need not activate lights or siren immediately if waiting reduces risks such as flight and that objective evidence of pursuit is not strictly required.

criminal lawprocedure

The case involved Robroy Wall, Jr., who was convicted of first degree murder and a firearm enhancement for the 2003 shooting death of Zachariah Street in Ada County, Idaho, after testimony showed Wall and accomplices killed Street over suspicions he had informed on gang members. Wall appealed, contending that the district court committed reversible error by substituting a new verdict form and instruction after the jury had begun deliberations, which he argued effectively directed a verdict on murder and functioned as a prohibited dynamite instruction. The Idaho Court of Appeals affirmed the conviction, reasoning that the new form remained consistent with the existing jury instructions on the elements of first degree murder and did not alter the required findings or indicate the jury had reached an impasse.

criminal law

Curtis Glenn Hartshorn pled guilty pursuant to plea agreements to possession of a controlled substance with intent to deliver, escape, issuing a check without funds, and grand theft (via Alford plea), after which the district court imposed sentences including probation that was later revoked. Hartshorn later filed a pro se motion to withdraw his guilty plea to grand theft and I.C.R. 35 motions seeking sentence reductions based on mental health and substance abuse issues. The district court denied the motion to withdraw the plea and the Rule 35 motions. The Idaho Court of Appeals affirmed, concluding that a post-judgment hearing on withdrawing a guilty plea is not a critical stage under the Sixth Amendment so counsel was not required, and that Hartshorn had not shown new information warranting leniency on the sentences. The court noted Hartshorn had not pursued ordered substance abuse treatment and that prejudice at such a late stage was minimal.

criminal lawprocedure

The case involved Max Ritchie Cooke, who was convicted by a jury of second degree kidnapping, aggravated battery, and assault following an incident in which he drove a vehicle into a tree, injuring his wife during their separation. Cooke appealed his convictions and the partial denial of his post-conviction relief petition, arguing that the trial court erred by admitting evidence of his prior threats under I.R.E. 404(b), that the prosecutor committed misconduct in closing argument, and that his trial counsel was ineffective for failing to challenge his wife's competency to testify or investigate possible false memories. The Idaho Court of Appeals affirmed the judgment of conviction and the partial denial of post-conviction relief. The court reasoned that the threats evidence was relevant to negate any claim of accident and its probative value was not outweighed by prejudice, that any prosecutorial statements did not rise to fundamental error, and that Cooke failed to show deficient performance or prejudice because no evidence established his wife's incompetence or the existence of false memories.

criminal lawprocedure

In State v. Hawkins, the defendant was convicted of robbery after two bank robberies in Boise in which he demanded money via notes and later made statements implicating himself while in custody following a standoff with police. The appeal challenged the district court's failure to sua sponte order a psychiatric evaluation and hearing on the defendant's competence to stand trial or represent himself, despite extensive pretrial and trial evidence of delusions, inconsistent statements about government agencies, and bizarre behavior. The Court of Appeals held that this evidence created a bona fide doubt about competency sufficient to require evaluation, so the district court abused its discretion by not ordering one. The judgment of conviction was therefore vacated and the case remanded for further proceedings, including a competency determination before any retrial.

criminal lawprocedure

This case involved Saint Alphonsus Regional Medical Center's appeal of a district court order dismissing its petition for judicial review of Ada County's denial of medical indigency assistance to a homeless patient who incurred over $26,000 in hospital costs for psychiatric treatment. The district court had ruled that medical providers lack standing to seek review of such county decisions under Idaho Code § 31-3505G. The Idaho Supreme Court vacated the dismissal and remanded for further proceedings, holding that providers do have standing based on its concurrent ruling in a similar case and prior precedents interpreting the Medical Indigency Act, even after 1996 statutory amendments. The court denied the hospital's request for attorney fees on appeal, finding the standing issue presented a question of first impression.

healthcareprocedure