State v. Angela Marie Boehm
158 Idaho 294
| Idaho Ct. App. | 2015Background
- Angela Boehm was cited after a two-vehicle crash for DUI and driving without privileges; two breath samples showed .192 and .183 BAC.
- In magistrate court Boehm moved to sever the counts, filed a motion in limine to exclude breath-test evidence, and moved to compel discovery; the magistrate denied the sever and compel motions and deferred ruling on the motion in limine.
- Boehm entered a conditional guilty plea preserving appeal of those pretrial rulings.
- After McNeely was decided, Boehm moved to withdraw her plea, arguing McNeely changed Fourth Amendment law and affected Idaho’s implied-consent scheme; the magistrate denied the motion.
- The district court affirmed the magistrate on all issues; the Court of Appeals affirmed the district court.
Issues
| Issue | Boehm's Argument | State's Argument | Held |
|---|---|---|---|
| Motion to sever DUI from driving without privileges | Joinder unfairly prejudices jury (risk of using bad-character inference) | No showing of actual prejudice; joinder proper and jury can compartmentalize | Denial affirmed — no abuse of discretion; issues were distinct and jury instructions mitigate risk |
| Motion to compel / Due process | Prosecutor failed to seek out or provide requested documents, violating due process and effective assistance | Prosecutor complied with I.C.R. 16 and disclosed what was required; no withholding of material exculpatory evidence | Denial affirmed — no Brady/due-process violation; prosecutor has no general duty to collect all evidence; I.C.R.16 procedures satisfied |
| Motion in limine to exclude breath-test evidence | Breath-testing SOPs were invalid because not promulgated under APA, so results inadmissible | Court may defer admissibility ruling until trial foundation is developed | Denial (deferred) affirmed — magistrate properly exercised discretion to defer ruling until evidence presented at trial; issue not preserved on appeal |
| Motion to withdraw conditional guilty plea (post-McNeely) | McNeely changed Fourth Amendment law regarding warrantless testing and affected Idaho’s implied-consent statute, providing a just reason to withdraw plea | McNeely did not directly decide implied-consent issues; no sufficient showing that McNeely gave a just reason to withdraw plea | Denial affirmed — McNeely did not directly alter the implied-consent question in a way that justified withdrawal; trial court acted within discretion |
Key Cases Cited
- State v. Abel, 104 Idaho 865, 664 P.2d 772 (Idaho 1983) (joinder prejudice analysis looks to whether evidence would be admissible in separate trials)
- United States v. Johnson, 820 F.2d 1065 (9th Cir. 1987) (jury can compartmentalize evidence; denial of severance not an abuse where issues are simple and distinct)
- State v. Hester, 114 Idaho 688, 760 P.2d 27 (Idaho 1988) (trial court may defer ruling on motions in limine until trial when evidentiary foundation is lacking)
- Missouri v. McNeely, 133 S. Ct. 1552 (U.S. 2013) (natural dissipation of alcohol does not create per se exigency to justify warrantless blood tests)
- State v. Wulff, 157 Idaho 416, 337 P.3d 575 (Idaho 2014) (Idaho implied-consent statute not a per se exception to the warrant requirement)