Jaimi Dean Charboneau v. State
162 Idaho 160
Idaho2017Background
- Jaimi Charboneau was convicted of first-degree murder for killing his ex-wife Marilyn in 1984; two daughters (Tiffnie and Tira) testified at trial. Forensic evidence linked most bullets to a Remington .22 rifle Charboneau admitted firing.
- In 2011 Charboneau filed his fifth post-conviction petition after receiving a large envelope containing photocopies: a purported recantation letter from Tira (the "Tira Letter"), a typed affidavit from former sheriff Larry Gold, a forged "Balzer Statement," and notes/emails tied to a corrections employee (Shedd).
- The district court found the Tira Letter trustworthy and the Gold statement admissible, concluded the State suppressed the letter in violation of Brady or that it was newly discovered evidence, and granted a new trial.
- The State appealed; the Idaho Supreme Court reviewed whether the successive petition was barred by issues raised and rejected in Charboneau’s earlier (third) post-conviction petition and whether the new materials were admissible or Brady-material.
- The Supreme Court held the issues (Tira’s alleged recantation and claims of prosecutorial/law-enforcement-directed false testimony) were essentially the same as those litigated in Charboneau’s third post-conviction petition and therefore barred as successive; it also found the Gold affidavit inadmissible hearsay and the Tira Letter not material given admitted testimony and forensic evidence.
- Judgment reversed and petition ordered dismissed with prejudice; cross-appeal moot. The Court declined to alter bail pending finality because reversal was not yet final.
Issues
| Issue | Charboneau's Argument | State's Argument | Held |
|---|---|---|---|
| Whether fifth post-conviction petition was barred as successive | The Tira Letter and related documents are new Brady/newly discovered evidence justifying relief | Issues of Tira’s recantation and alleged prosecutorial coercion were raised in the third petition and thus successive and untimely | Petition barred as successive; issues earlier raised and rejected — dismissal with prejudice |
| Whether nondisclosure of Tira Letter violated Brady and was material | Letter showed Tira recanted and admitted she lied under prosecutor/detective direction; nondisclosure deprived defense | No evidence prosecutors or agents knew of the letter; even if withheld, letter contradicted Charboneau’s own admissions and forensic evidence, so not material | No Brady violation proven; letter not material to undermine confidence in verdict |
| Admissibility of Larry Gold statement | Gold’s affidavit supports that others knew of the Tira Letter and clerk intercepted it | Gold’s statement is hearsay and recounts out-of-court statements by others; not covered by exceptions | Gold statement inadmissible hearsay within hearsay; cannot be used to prove its asserted facts |
| Reliability of envelope contents (forgeries/evidence planting) and attendant credibility | Envelope contents corroborate suppression and recantation narrative | Several items are forged (Balzer Statement) or unexplained; forgeries show manipulation and undermine reliability | Forgeries and unexplained provenance undercut trustworthiness; cannot rescue successive-petition claims |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor's duty to disclose materially exculpatory evidence)
- Kyles v. Whitley, 514 U.S. 419 (1995) (prosecutor must learn of favorable evidence known to others acting on government’s behalf)
- Strickler v. Greene, 527 U.S. 263 (1999) (materiality standard for Brady: reasonable probability of different outcome)
- Charboneau v. State, 144 Idaho 900, 174 P.3d 870 (2007) (successive post-conviction filing timing and related standards)
- State v. Charboneau, 116 Idaho 129, 774 P.2d 299 (1989) (criminal trial record and factual background)
- State v. Fetterly, 115 Idaho 231, 766 P.2d 701 (1988) (characterizing post-conviction relief as civil special proceeding)