Free Idaho Supreme Court - Criminal case summaries from Justia.
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Idaho Supreme Court - Criminal Opinions | Idaho v. Haws | Docket: 47800 Opinion Date: October 2, 2020 Judge: Stegner Areas of Law: Constitutional Law, Criminal Law | Law enforcement used confidential informants to make several purchases of controlled substances from Darius Haws and his brother between April and May of 2015. While out on bond, Haws went to the residence of a female acquaintance. The woman called the police to report that Haws was trespassing. As a responding law enforcement officer approached Haws, the officer could “smell a strong odor of alcohol coming from [Haws’] breath.” When the officer attempted to arrest Haws, Haws resisted, swinging his arm and hitting the officer. Based on this altercation, the State charged Haws with battery on a police officer, resisting and obstructing an officer, criminal trespass, and disturbing the peace. Haws’ guilty pleas were entered pursuant to plea agreements in which he waived his right to appeal his convictions or sentences. The district court sentenced Haws to two years fixed, with four years indeterminate, for the delivery charge; and one year fixed, with three years indeterminate, for the battery charge. The sentences were ordered to run consecutively. Initially, the district court retained jurisdiction over Haws, but after performing poorly during the period of retained jurisdiction, the district court relinquished jurisdiction and ordered the original sentences be served. On appeal, Haws argued the district court abused its discretion in relinquishing jurisdiction and that his sentences were excessive. In response, the State sought to have Haws’ appeal dismissed because Haws expressly waived his right to appeal his sentences in the plea agreements he signed. The Court of Appeals agreed, dismissing Haws’ challenge to his sentences and affirming the district court’s decision to relinquish jurisdiction over Haws. On appeal to the Idaho Supreme Court, Haws contended the Court of Appeals incorrectly held that he had forfeited the right to address the validity of his plea agreements by not raising an issue of validity of those waivers in his opening brief. Instead, Haws contended it was the State’s obligation to assert the applicability of the appellate waiver, and that he should have had the opportunity to respond in his reply brief. Additionally, Haws argued his appellate waiver was not made knowingly, intelligently, and voluntarily because the district court made a statement that conflicted with the written plea agreements by noting that Haws had the right to appeal his sentences. The Supreme Court found no reversible error and affirmed the district and appellate courts. | | Idaho v. Winkler | Docket: 47102 Opinion Date: October 2, 2020 Judge: Roger S. Burdick Areas of Law: Constitutional Law, Criminal Law | Brandon Lynn Winkler appealed a district court order denying his motion to dismiss a January 2019 felony charge for driving under the influence of alcohol. Despite Winkler having been pardoned for a 2006 felony DUI, the district court determined that it still counted as a prior felony DUI for purposes of charging Winkler with a felony under Idaho Code section 18-8005(9). On appeal, Winkler argued the district court erred in concluding that a pardon did not prevent a prior felony DUI from being used to enhance a subsequent DUI charge to a felony under Idaho Code section 18-8005(9). The Idaho Supreme Court concurred: the district court erred in allowing Winkler's prior DUI conviction to be used to enhance his pending DUI charge. As such, the order was reversed and the matter remanded for further proceedings. | |
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