Justia Family Law Opinion Summaries

In June 2016, Peter Franklin Goullette was driving with his child in the backseat when he struck and killed Kathy Stelzer and severely injured Zualita Updike, who were walking on the road. Goullette admitted to officers that he was attempting to buckle his son back in when he struck the victims. He was charged with vehicular manslaughter and reckless driving. Goullette entered a guilty plea while maintaining his innocence, known as an Alford plea. He later appealed his conviction, arguing that the district court abused its discretion when it accepted his guilty plea because it failed to inquire into the factual basis of his guilty plea.The case was first heard in the District Court of the First Judicial District of the State of Idaho, Bonner County, where Goullette was convicted. He then appealed to the Idaho Court of Appeals, which affirmed his conviction. Goullette subsequently filed a petition for review with the Supreme Court of the State of Idaho.The Supreme Court of the State of Idaho affirmed Goullette's conviction. The court held that the district court did not err in accepting Goullette’s Alford plea because the record as a whole demonstrated that Goullette entered a knowing, voluntary, and intelligent plea. The court also held that the district court did not err by failing to revisit the validity of Goullette’s plea at sentencing because the district court was not presented with evidence raising an obvious doubt as to Goullette’s guilt. View "State v. Goullette" on Justia Law

In this case, Develin Johnson appealed against the district court's decision that upheld his convictions for domestic battery and false imprisonment. The key issue in the appeal was the admissibility of Johnson's previous misdemeanor conviction for petit theft under Idaho Rule of Evidence 608(b) and whether the probative value of the evidence was substantially outweighed by the risk of unfair prejudice. Johnson argued that the district court erred in affirming the judgment of conviction because his misdemeanor conviction for theft was inadmissible under Idaho Rule of Evidence 608(b) and the probative value of the evidence was substantially outweighed by a danger of unfair prejudice. The Supreme Court of the State of Idaho affirmed the district court's decision, holding that the conduct leading to Johnson's 2013 misdemeanor conviction was probative of his character for truthfulness and that the prejudicial effect of the evidence did not substantially outweigh its probative value. View "State v. Johnson" on Justia Law

In this case, defendant Douglas Shane Thompson was convicted for domestic violence, and a no-contact order was put in place prohibiting him from contacting his minor son. Thompson appealed against the decision, arguing that there was no evidence that he posed a threat to his son and that the no-contact order violated his fundamental right to parent his son.The Supreme Court of the State of Idaho found that the lower court failed to provide adequate reasons for amending the no-contact order to prohibit all contact between Thompson and his son. The court concluded that the lower court did not exercise reason since it did not articulate any evidence that demonstrated a change in circumstances that justified the amendment of the no-contact order. It was also noted that the court did not explain what circumstances would need to change before Thompson could seek to reinitiate contact with his son.The court also observed that Thompson's argument that the no-contact order effectively terminated his parental rights was not sufficiently preserved for appeal. The court acknowledged the complexities when a judge not regularly dealing with family law issues has to analyze often competing interests involved.Therefore, the court reversed the decision of the lower court to amend the no-contact order and remanded the case back to the district court for further proceedings. View "State v. Thompson" on Justia Law

Defendant John Schulz appealed his conviction of felony domestic battery and the attempted strangulation of his fifteen-year-old daughter. Both charges required the state to prove that the daughter was Defendant's "household member" as defined by the applicable statute. The district court granted Defendant's motion to dismiss based on the fact that she did not fall within that definition. Because the Supreme Court found that the definition of "household member" plainly limited the application to "intimate partners" and thus, did not extend to a child living with her father, the Court affirmed.