State v. Adamcik, 152 Idaho 445

Background

Adamcik was convicted of first‑degree murder and conspiracy to commit first‑degree murder after planning and stabbing Stoddart; the crime was committed September 22–23, 2006, with evidence showing both Adamcik and Draper participated and two knives used; BRC site items, notebook, and tape captured planning and reactions; the State introduced autopsy, forensics, and video evidence including the BRC tape; interrogations occurred September 24 and 27, 2006, with Miranda rights and a later suppression dispute regarding statements after invocation of counsel.
Two knives used in the murder, one serrated and one non‑serrated, were linked to wounds potentially fatal; doctors testified to multiple stab wounds, and the evidence supported a theory of conjoint liability; the information charged Adamcik with murder by purchasing knives and stabbing, sufficient under Idaho law to convict as a principal or accomplice.
The district court admitted extensive evidence and considered both principal and accomplice theories under Idaho law abolishing the distinction; the defense argued insufficient direct evidence of a fatal stab by Adamcik, while the State argued aiding and abetting liability was valid; the majority affirmed the conviction under an aiding/abetting framework notwithstanding the charging language.
Adamcik appealed the denial of suppression, jury instruction adequacy, and other trial issues; the Court held the Miranda waiver valid, parent invocation of counsel permissible, and subsequent statements not the product of custodial interrogation; malice instructions were not misleading; and there was no fundamental error in closing arguments.
The court rejected the lying‑in‑wait theory as a basis for error given the overall instruction scheme; it affirmed the sentence as not cruel and unusual, and denied Rule 35 relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for first‑degree murder	Adamcik challenges whether substantial evidence showed he personally stabbed Stoddart.	State failed to tie Adamcik to a fatal stab; only accomplice theory supported.	Sufficient evidence supported guilt beyond a reasonable doubt.
Motion to suppress statements after invocation of counsel	Parents could invoke Fifth Amendment rights on behalf of Adamcik; invocation not honored.	District court erred by denying suppression of post‑invocation statements.	District court did not err; voluntary waiver and non‑custodial elicitation issues resolved in favor of State.
Unanimity instruction requirement	Unanimity required on specific act causing death.	No unanimity instruction needed because liability is principal or accomplice; acts consolidated.	No unanimity instruction required; no fundamental error.
Malice instruction correctness	Malice instructions lowered the State's burden; ICJI 702 mismatch.	Instructions properly framed; no lowering of the burden.	Malice instructions did not misstate the law; burden not lowered.
Lying‑in‑wait theory and amendments to information	Amended information did not allege lying‑in‑wait; trial included that concept.	No variance; lying‑in‑wait is a form of premeditation; not fundamental error.	No fundamental error; proper interpretation of the charge and instructions.

Key Cases Cited

State v. Johnson, 145 Idaho 970 (2008) (abolished principal/aiders-and-abettors distinction; charging sufficiency covers both theories)
State v. Severson, 147 Idaho 694 (2009) (unanimity requirements and murder instructions; context of closing arguments)
State v. Owen, 73 Idaho 394 (1953) (equal guilt for defendants in concert; principles of aiding/abetting under historical context)
State v. Ayres, 70 Idaho 18 (1949) (information may charge principal and rely on aiding/abetting theory; due process concerns)
State v. Butcher, 137 Idaho 125 (Ct.App.2002) (Butcher: guidance on aiding/abetting instruction and surplusage in information)