Latest 3 Cases: Idaho v. Dix (Constitutional Law), Idaho v. Haggard (Constitutional Law), Idaho v. Rodriguez (Constitutional Law)

Would Eliminating Qualified Immunity Substantially Deter Police Misconduct?

MICHAEL C. DORF

Cornell law professor Michael C. Dorf discusses the proposal that eliminating or substantially reducing the qualified immunity currently enjoyed by police officers would address racism and police brutality. Although the idea has lately garnered some bipartisan support and could potentially have some benefit, Dorf describes two reasons to be skeptical of the suggestion. He concludes that for all of its flaws, qualified immunity may actually facilitate the progressive development of constitutional rights.

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Idaho v. Dix

Docket: 47112

Opinion Date: June 10, 2020

Judge: Brody

Areas of Law: Constitutional Law, Criminal Law

Over a period of several months, William Dix bought several thousand dollars’ worth of goods from Grainger Supply on credit. On the same days he bought the goods, he pawned them. Dix was charged with grand theft and burglary, and pleaded not guilty to both counts. At trial, the State argued that Dix committed theft by obtaining the goods on credit without intending to pay for them, and committed burglary by receiving loans from the pawn shop in exchange for the goods based on false representations that he owned them. After the close of the State’s case-in-chief, Dix moved for a judgment of acquittal under Idaho Criminal Rule 29 on both charges, arguing that under Idaho v. Bennett, 246 P.3d 387 (2010), he became the owner of the goods once he obtained possession of them from Grainger, and as the owner, he could lawfully pawn them. The district court denied Dix’s motion, and the jury subsequently returned guilty verdicts on both counts. After trial, Dix renewed his Rule 29 motion on the burglary charge, and this motion was also denied. The district court entered an order withholding judgment and placing Dix on probation for eight years. Dix timely appealed, and the Court of Appeals affirmed. Upon certiorari review, the Idaho Supreme Court reversed Dix’s convictions and remanded the case to the district court with instructions to enter a judgment of acquittal on both counts.

Idaho v. Haggard

Docket: 47577

Opinion Date: June 10, 2020

Judge: Roger S. Burdick

Areas of Law: Constitutional Law, Criminal Law

Clinton Haggard appealed a district court’s decision to affirm a magistrate court’s judgment of conviction. After a trial, the magistrate court found Haggard guilty of misdemeanor domestic battery in violation of Idaho Code section 18-918(3)(b). The issue presented for the Idaho Supreme Court's review was whether aggard effectively waived his right to a jury trial. The Court found Haggard’s waiver was ineffective because the magistrate court did not, in open court, inquire into whether the waiver was knowing, intelligent, and voluntary. The Court therefore reversed the district court’s decision and remanded this case with instructions to the district court to remand this case to the magistrate court with instructions to vacate the judgment of conviction.

Idaho v. Rodriguez

Docket: 46333

Opinion Date: June 10, 2020

Judge: Brody

Areas of Law: Constitutional Law, Criminal Law

John Rodriguez sold a firearm to an individual who had visible gang tattoos and had previously identified himself as a member of the Norteno gang, but who was actually an informant paid by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The State charged Rodriguez with two counts of providing firearms to criminal gang members under Idaho Code section 18-8505 and a sentencing enhancement for providing the firearm to further criminal gang purposes under Idaho Code section 18-8503(1)(b). After trial, the jury returned a verdict of guilty as to Count I but not guilty as to Count II and answered "no" to the sentencing enhancement question. The district court suspended a unified sentence of ten years and placed Rodriguez on probation for ten years. Rodriguez appealed, arguing his conviction should have been vacated because criminalizing the sale or transfer of firearms to gang members without the intent to further gang activity, Idaho Code section 18-8505 violated rights guaranteed by the federal Constitution: the freedom of association under the First Amendment, the right to bear arms under the Second Amendment, and the due process requirement of personal guilt under the Fourteenth Amendment. Finding that Rodriguez forfeited his constitutional challenges by failing to present them to the trial court, the Idaho Supreme Court affirmed.