Sarah Marie Johnson v. State
162 Idaho 213
Idaho2017Background
- In 2003 Sarah Johnson (age 16) was convicted by a jury of murdering her parents and sentenced to two fixed life terms plus a gun enhancement; conviction affirmed on direct appeal after procedural history correcting a late notice of appeal.
- Physical evidence recovered included a bloody bathrobe with Johnson’s DNA and paint chips, gloves, ammunition, a guesthouse key, and .264 rifle kept in a guesthouse; some fingerprints and DNA were unidentified at trial.
- Post-conviction proceedings produced (1) a claim seeking additional DNA testing under Idaho Code § 19-4902, (2) an Eighth Amendment challenge under Miller/Montgomery to her juvenile life sentences, and (3) claims alleging ineffective assistance by post-conviction counsel (a successive-petition issue).
- The district court denied DNA testing (finding re-running previously profiled samples against updated databases was not new “technology,” and that new testing of low-quantity samples lacked the scientific potential to show Johnson was probably innocent), dismissed the Miller claim as procedurally/time-barred but on appeal addressed the merits, and dismissed the claims attacking post-conviction counsel under Murphy.
- On appeal the Idaho Supreme Court affirmed: (1) statutory interpretation bars re-running already-profiled samples against new databases as a new technology; (2) advanced testing of previously untestable samples would not more likely than not show Johnson’s innocence when weighed against trial evidence; (3) Miller/Montgomery apply but sentencing court had considered youth so no relief; and (4) Murphy remains good law, so ineffective-assistance-of-post-conviction-counsel claims do not justify a successive petition in Idaho state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether re-running previously profiled/unmatched DNA against current databases is "technology" under I.C. § 19-4902(b) | Johnson: availability of new profiles (Hill and expanded CODIS) is new knowledge/technology warranting comparison | State: mere availability of additional profiles is not a new testing technology under statute | Court: Denied — database growth or new profiles is not "technology" under § 19-4902(b) |
| Whether advanced testing of previously untestable low-quantity samples meets § 19-4902(e)(1) (scientific potential to show >50% probability of innocence) | Johnson: new amplification methods could identify a third-party shooter and thus more likely than not show innocence | State: even if identified, DNA cannot prove timing or that person was the shooter; trial evidence strongly implicates Johnson | Court: Denied — district court correctly weighed trial evidence and found testing unlikely to make it more probable than not that Johnson is innocent |
| Whether Miller and Montgomery render Johnson's fixed-life juvenile sentences unconstitutional | Johnson: Miller/Montgomery require resentencing because life sentences for juveniles require youth-focused consideration and Miller is retroactive | State: claim forfeited/untimely or, alternatively, sentencing already considered youth | Court: Miller/Montgomery apply retroactively, but sentencing court adequately considered youth; claim fails on the merits |
| Whether Murphy v. State should be overruled so ineffective assistance of post-conviction counsel can excuse successive-petition bars | Johnson: Martinez and Trevino (federal equitable exceptions) justify overruling Murphy to allow such claims in state court | State: Murphy remains controlling; Martinez is nonbinding, equitable federal rule | Court: Declined to overrule Murphy — Martinez is not binding on state courts; ineffective assistance of post-conviction counsel is not a "sufficient reason" under Idaho law |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (juvenile mandatory life without parole unconstitutional; sentencer must consider youth)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (Miller substantive rule is retroactive)
- Murphy v. State, 156 Idaho 389, 327 P.3d 365 (2014) (ineffective assistance of post-conviction counsel is not sufficient reason to allow a successive petition under Idaho law)
- Fields v. State, 151 Idaho 18, 253 P.3d 692 (2011) (DNA test results alone cannot establish innocence absent evidence linking samples to the perpetrator)
- Coleman v. Thompson, 501 U.S. 722 (1991) (no constitutional right to counsel in state post-conviction proceedings)
- Martinez v. Ryan, 566 U.S. 1 (2012) (equitable federal habeas exception for ineffective-assistance-of-trial-counsel claims when initial post-conviction counsel was absent/ineffective)
- Trevino v. Thaler, 569 U.S. 413 (2013) (extends Martinez to jurisdictions where procedural framework limits ability to raise ineffective-assistance claims on direct appeal)
- State v. Johnson, 145 Idaho 970, 188 P.3d 912 (2008) (direct-appeal decision referenced)
- State v. Johnson, 156 Idaho 7, 319 P.3d 491 (2014) (post-conviction appeal addressing fingerprint evidence)