State v. Alvarez, 48134

Alvarez, driving a silver SUV, rear-ended a black SUV carrying a mother and three children at a Meridian intersection; the silver SUV initially pulled over but then left the scene.
Another officer found Alvarez near her damaged vehicle; she initially denied driving but later admitted hitting the black SUV and leaving, and said she thought there could have been injuries.
Occupants of the black SUV reported neck/head/shoulder pain (rating pain levels on a 1–10 scale); none were transported or presented medical records at trial.
Officers observed significant vehicle damage (black SUV pushed ~a car length, glass on road; Alvarez’s SUV with severe front-end damage); Alvarez tested positive for methamphetamine.
Alvarez was charged with felony leaving the scene of an injury accident (I.C. § 18-8007) and misdemeanor operation under the influence; a jury convicted her of both counts and she appealed only the leaving-the-scene conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: whether evidence proved an "injury" and Alvarez knew or had reason to know of it	State: testimony of pain by occupants, damage to vehicles, and Alvarez’s admission supported inference of injury and her knowledge	Alvarez: pain alone is insufficient to prove an "injury" under Mead; no medical treatment or signs at scene; couldn’t be expected to know occupants’ condition 20–30 minutes later	Affirmed. Court held pain testimony and vehicle damage provide circumstantial substantial evidence of injury and of Alvarez’s reason to know.
Jury instruction: whether court erred by instructing that “no specific degree of injury is required”	State: the instruction correctly states law per Mead; instruction was proper	Alvarez: instruction misstates law, misleads jury, and lowers burden of proof (raised on appeal)	Not preserved. Alvarez objected only that instruction was non-ICJI; she conceded at trial it was an accurate statement and did not argue it was misleading, so appellate challenge was forfeited. Court also noted the instruction is consistent with Mead.

State v. Mead, 145 Idaho 378, 179 P.3d 341 (Ct. App. 2008) ("injury" means any harm or damage; degree not required)
State v. Severson, 147 Idaho 694, 215 P.3d 414 (2009) (circumstantial evidence alone may be substantial evidence)
State v. Herrera-Brito, 131 Idaho 383, 957 P.2d 1099 (Ct. App. 1998) (standards for appellate sufficiency review)
State v. Bodenbach, 165 Idaho 577, 448 P.3d 1005 (2019) (jury-instruction objections must be timely preserved)
State v. Richardson, 168 Idaho 25, 478 P.3d 754 (Ct. App. 2020) (preservation rules for instruction challenges)
State v. Parish, 79 Idaho 75, 310 P.2d 1082 (1957) (knowledge of injury may be proven by surrounding facts and circumstances)