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

Jennifer Blake sued Delbert Starr for personal injuries after Starr, operating a front-end loader on a highway construction project, struck and ran over her while she worked as a flagger for a subcontractor. The district court granted summary judgment to Starr, and the Idaho Supreme Court affirmed. The court held that Starr was exempt from tort liability under Idaho Code § 72-209(3) because he was an employee of the primary contractor, which qualified as Blake's statutory employer under the worker's compensation scheme. The core reasoning was that the Idaho Worker’s Compensation Act provides the exclusive remedy for workplace injuries, extending immunity to statutory employers and their employees to fulfill the statute's purpose of certain relief without fault and limited liability. The appeal also addressed but denied attorney fees to Starr.

labor & employmenttorts & liability

The case involved St. Luke's Regional Medical Center appealing a district court order dismissing its petition for judicial review of an Ada County Board of Commissioners decision denying medical indigency assistance for a patient's cancer treatment under Idaho's Medical Indigency Act. The district court had ruled that the hospital lacked standing to seek review under Idaho Code § 31-3505G. The Idaho Supreme Court vacated the dismissal and remanded the case, holding that medical providers have standing to request judicial review of final county board decisions denying such applications. The court reasoned that this outcome aligned with the Act's dual legislative purpose of providing care for indigents and compensating providers, was consistent with prior precedents like Carpenter and Intermountain Health Care II, and avoided absurd inconsistencies in appellate rights at different procedural stages.

healthcareprocedure

In State v. Huntsman, the defendant was convicted of first-degree murder with a firearm enhancement and two counts of second-degree kidnapping after evidence showed he participated in abducting and killing a man suspected of theft, along with related kidnappings. Huntsman appealed, arguing that the state's dismissal and refiling of identical charges violated his speedy trial rights, that the appellate court lacked jurisdiction over claims from the dismissed case, and that various trial errors occurred including improper admission of late-disclosed witness testimony and failure to exclude witnesses under pretrial orders. The court affirmed the convictions, holding it had no jurisdiction to review the initial dismissal order because no timely appeal was filed, that Huntsman failed to demonstrate prejudice from the refiling or other alleged errors, and that the trial court's rulings on evidentiary issues did not warrant reversal. The opinion focused on procedural requirements for appeals and the lack of reversible error in the proceedings leading to the jury verdict.

criminal lawprocedure

This case involved Evan Edward Morgan's appeal of his designation by the Sexual Offender Classification Board as a violent sexual predator following his 1998 guilty plea to lewd and lascivious conduct with a minor and possession of sexually exploitative material. The district court affirmed the board's designation after denying Morgan access to certain underlying documents and reviewing evidence including a psychosexual evaluation that classified him as a pedophilic offender with a high risk of reoffending, based on his history of contact with multiple victims and collection of child pornography. Morgan argued that his physical disability (confinement to a wheelchair with no feeling below the waist) and lack of full access to records undermined the designation, but the court held that the statutory process was followed, the offender could challenge only miscalculation or specific facts, and the evidence supported the high-risk finding under the Sexual Offender Registration Act. The Court of Appeals affirmed, concluding the district court properly reweighed the evidence and that Morgan fit the statutory definition of a violent sexual predator.

criminal lawprocedure

In State v. Doe, a juvenile was charged under the Juvenile Corrections Act with violating a city curfew ordinance, and the magistrate took judicial notice of the ordinance despite the juvenile's objection that it needed to be proven. The district court affirmed this ruling on appeal, and the Idaho Court of Appeals also affirmed. The court reasoned that under Idaho Rule of Evidence 201, the ordinance qualified for judicial notice because it was generally known within the jurisdiction or capable of accurate and ready determination, and precedent allowed courts to notice municipal ordinances they enforce. The appellant had not contested that the specific ordinance met these criteria for judicial notice.

criminal lawprocedure

In State v. Mitchell, the defendant appealed his convictions for aggravated battery, robbery, and burglary, along with his sentences, arguing insufficient evidence to corroborate an accomplice's testimony and to prove intent for the battery charge, plus error in denying his motion to reduce the sentence. The Idaho Court of Appeals affirmed the judgment and sentences. The court held that independent evidence, including DNA, shell casings, witness observations, and Mitchell's attempts to influence testimony, sufficiently corroborated the accomplice's account of the planned robbery. It also found substantial evidence that Mitchell acted as the instigator who supplied at least one firearm, supporting the jury's finding of intent for aggravated battery. Finally, the court concluded that even if some sentencing information was inaccurate, it did not form the basis for the sentence given Mitchell's role and criminal history, so there was no abuse of discretion.

criminal lawprocedure

In State v. Deisz, the defendant was convicted of aggravated battery and aggravated assault after firing a shot at police officers who entered his home to retrieve his wife's belongings pursuant to a domestic protection order. Deisz appealed the district court's denial of his motion to suppress evidence obtained after the warrantless entry and its consideration of a victim impact statement during sentencing. The court assumed without deciding that the initial entry was unlawful but held that the evidence of the shooting need not be suppressed because police did not exploit the entry to obtain that evidence. It further ruled that the victim impact statement was admissible as victim input and that the sentencing judge properly based the sentence on relevant factors without improper reliance on the statement. The judgment of conviction and sentences were affirmed.

criminal lawprocedure

In State v. DeWitt, the state appealed a district court decision upholding a magistrate's suppression of blood test evidence obtained from an unconscious defendant suspected of misdemeanor DUI after a single-car accident. The court held that the warrantless blood draw did not violate the Fourth Amendment. It reasoned that Idaho's implied consent statute applies to unconscious drivers, eliminating any right to refuse testing, and that exigent circumstances independently justified the search due to the rapid dissipation of alcohol in the blood. The opinion reversed the suppression order and remanded for further proceedings.

criminal lawcivil rightsprocedure

In State v. Morgan, the defendant was convicted by a jury of two counts of lewd conduct with a minor child under sixteen based on allegations that he sexually abused a four-year-old boy. Morgan appealed, arguing that the district court erred in denying his motion for a mistrial and subsequent motion for a new trial because the prosecutor improperly commented in front of the jury that Morgan would testify and could testify about certain statements, which Morgan claimed infringed on his constitutional right to remain silent. The Idaho Court of Appeals affirmed the conviction, holding that any error from the prosecutor's comments was harmless because Morgan ultimately took the stand and testified on his own behalf, diluting any potential prejudice. The court also upheld the denial of the new trial motion, noting that the statutory grounds for such relief were not met once the mistrial issue was resolved in the state's favor.

criminal lawprocedure

In State v. Salois, the defendant was charged with drug possession and paraphernalia offenses after a traffic stop led to a vehicle search that uncovered cocaine, hydrocodone, and related items. The district court granted her motion to suppress the evidence and statements, finding on alternative grounds that the stop lacked reasonable suspicion, was unconstitutionally prolonged, and that any Miranda waiver was invalid due to lack of proof she understood her rights. The State appealed, arguing the officer had reasonable suspicion because the vehicle appeared to lack plates. The appellate court affirmed, holding that the record, including the stop video, supported the finding that the officer had seen the visible temporary registration before initiating the stop and thus lacked reasonable suspicion of criminal activity, making further analysis of the other grounds unnecessary.

criminal lawprocedure

In State v. Cardenas, police officers approached the defendant in a driveway while searching for a runaway juvenile, asked him questions, obtained consent to search a vehicle's glove box, and ultimately arrested him after discovering stolen checks, a bullet, marijuana, and later a gun and drugs pursuant to a warrant. The district court granted the defendant's motion to suppress all evidence, finding that his detention became unlawful once he denied knowing the runaway. On appeal, the Idaho Court of Appeals affirmed suppression of the physical evidence because the initial encounter was an illegal seizure under the Fourth Amendment rather than consensual and the warrant was tainted by that illegality, but reversed suppression of the defendant's post-Miranda statements because the three-hour delay, proper warnings, and lack of flagrant misconduct attenuated the taint from the unlawful detention. The case was remanded for further proceedings.

criminal lawprocedurecivil rights

The case involved Michael Ronald Reese Crabtree, who was charged with aggravated assault along with misdemeanors for leaving the scene of an accident and driving without privileges. Following a jury trial, he was convicted on all counts and received a unified sentence of five years with two years determinate for the aggravated assault, plus concurrent 180-day terms for the other offenses. Crabtree appealed, claiming the district court abused its discretion with an excessive sentence. The Idaho Court of Appeals affirmed the judgment and sentence, holding that the punishment was within statutory limits and reasonable based on the nature of the offense and the offender's character.

criminal law

Francisco Garcia appealed his conviction for trafficking in marijuana, challenging the district court's denial of his motion to suppress evidence found during a warrantless search of his truck at a Boise campground. Officers had responded to a report of men smoking marijuana, observed Garcia and others passing what appeared to be a marijuana cigarette, confronted the group, and obtained Garcia's consent to a pat-down and later a vehicle search after informing them that cooperation would lead to citations rather than arrests. The court affirmed the denial of the motion to suppress, concluding that the officers had probable cause to arrest based on observed drug activity, that Garcia's consent to the truck search was voluntary and not coerced by threats against innocent parties, and that the evidence was not suppressible as fruit of a Miranda violation.

criminal lawprocedure

In State v. Zuniga, the defendant was convicted by a jury of possession of methamphetamine after police recovered the drugs during a chase that followed an initial detention. Zuniga moved to suppress the evidence, arguing that the detective lacked reasonable suspicion to detain him at the outset and that the drugs were therefore fruit of an unlawful seizure. The district court agreed the detention was unsupported but ruled that the seizure ended when Zuniga fled, so the evidence discarded during the pursuit was admissible under California v. Hodari D. The Court of Appeals affirmed, holding that once Zuniga refused to submit to the officer’s authority by running away, he was no longer seized and the discarded contraband was not subject to suppression.

criminal lawprocedurecivil rights