State v. Campbell
170 Idaho 232
| Idaho | 2022Background
- In 2019 a 17-year-old Cory Campbell was charged under Idaho Code §20-509 (automatic adult waiver) with multiple sexual-offense felonies alleging sexual assaults of ten minors; he pleaded guilty to two amended counts of battery with intent to commit rape and the State dismissed the other counts.
- At the March 6, 2020 sentencing the court orally imposed a 20-year determinate term on Count I and a 20-year indeterminate term on Count II, but the oral pronouncement was internally ambiguous about fixed/indeterminate language and did not clearly state concurrency; the written judgment stated the terms would run consecutively.
- Campbell filed post-conviction motions (I.C.R. 35 and 36) arguing the written judgment conflicted with the oral sentence, that the automatic waiver statute was unconstitutional (depriving the district court of jurisdiction), and seeking leniency; the district court set a limited resentencing to clarify the ambiguity and later entered an amended judgment clarifying consecutive service.
- The State sought an in camera review of documents relating to an Instagram account (created six days after sentencing) that identified victims; the district court found the post was not Brady material because it was created after sentencing and not material to guilt or punishment.
- Campbell appealed the amended judgment and denial of his Rule 35 motions; the Idaho Supreme Court affirmed: it held the oral sentence was ambiguous and properly clarified at resentencing, rejected the constitutional attack on §20-509 as waived and controlled by Orozco, found no abuse of sentencing discretion, denied Rule 35(b) relief, and rejected the Brady claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ambiguity between oral pronouncement and written judgment; proper remedy (I.C.R. 36 vs. resentencing) | State: oral pronouncement was ambiguous; resentencing to clarify was proper | Campbell: oral pronouncement controlled and was unambiguous; written judgment should have been conformed under Rule 36, not resentenced | Court: oral pronouncement was ambiguous; resentencing to clarify and amended judgment were proper (Rule 36 not available for substantive corrections) |
| Constitutionality of automatic waiver (§20-509) and subject-matter jurisdiction to sentence | Campbell: automatic waiver violates due process; district court lacked jurisdiction; Rule 35(a) may correct illegal sentence | State: waiver issue was waived by guilty plea; Orozco supports constitutionality; Rule 35(a) improper vehicle | Court: challenge waived by guilty plea (personal jurisdiction/waiver); Rule 35(a) not the correct mechanism for constitutional challenge; Orozco controls — waiver constitutional |
| Sentencing abuse of discretion; failure to consider youth / Eighth Amendment (Miller/Graham/Roper) | Campbell: court failed to adequately weigh juvenile status, mitigating evaluations, and youth-related Eighth Amendment protections; sentence excessive | State: court considered youth and juvenile sentencing jurisprudence but properly weighed aggravating factors (serial, predatory conduct) | Court: sentencing within statutory bounds; judge considered youth and relevant precedent; Miller inapplicable (not life without parole); no abuse of discretion or Eighth Amendment violation |
| Brady claim re: Instagram posts identifying victims created after sentencing | Campbell: prosecutor should have disclosed exculpatory/impeaching material or in camera review; materiality not required to trigger disclosure under Brady or ethical rules | State: posts were created after plea and sentencing and thus not material to guilt/punishment; in camera review appropriate | Court: applied Brady materiality standard; posts created after sentencing were immaterial to sentence outcome and not Brady material; district court did not err |
| Rule 35(b) motion for leniency (new evidence about harms of incarcerating juveniles in adult prisons) | Campbell: new research shows increased violence and reduced treatment efficacy for juveniles in adult prisons, supporting reduction | State: those points merely repackage youth mitigation already considered at sentencing; not new, case-specific evidence | Court: information was not new or case-specific; district court did not abuse discretion in denying Rule 35(b) relief |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (juveniles categorically exempt from death penalty)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles unconstitutional)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for non-homicide juvenile offenders unconstitutional)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose evidence favorable to accused that is material to guilt or punishment)
- Strickler v. Greene, 527 U.S. 263 (1999) (elements and materiality standard for Brady violations)
- State v. Orozco, 168 Idaho 274 (2021) (upholding constitutionality of Idaho's automatic waiver statute)
- State v. Shanahan, 165 Idaho 343 (2019) (Miller rationale applies only to sentences that are functional equivalents of life without parole)
- State v. Burnight, 132 Idaho 654 (1999) (juvenile jurisdiction via statutory waiver is personal and subject to waiver)
- State v. Wallace, 116 Idaho 930 (Ct. App. 1989) (oral pronouncement controls unless ambiguous; clerical errors may be corrected under I.C.R. 36)
- State v. Allen, 144 Idaho 875 (Ct. App. 2007) (Rule 36 cannot be used to substantively alter a sentence to reflect an unstated intent)
- State v. Bosier, 149 Idaho 664 (Ct. App. 2010) (concurrent sentence result when court fails to specify concurrency absent contrary intent)