State v. James Darnell Black, 161 Idaho 867

James Darnell Black pled guilty to one count of criminal possession of a financial transaction card; other charges were dismissed under a plea agreement.
The PSI and related records report a long history of mental-health problems: prior diagnoses (depression, anxiety, bipolar disorder, schizophrenia alleged), past psychiatric treatment, at least one prior suicide attempt, and treatment while incarcerated including psychotropic medication.
A GAIN screening indicated possible bipolar disorder, generalized anxiety disorder, recurrent major depressive disorder, and ADHD; a § 19-2524 mental-health examiner acknowledged potential serious mental illness but recommended no additional assessment because jail treatment was ongoing.
Black (pro se and through counsel) moved under I.C. § 19-2522 for a court-ordered psychological evaluation before sentencing, arguing his mental condition would be a significant sentencing factor and bearing on impulse control.
The district court denied the request, stating no reason to believe mental condition would be significant and that good cause was not shown, then imposed a determinate five-year sentence without articulating sentencing factors.
The Court of Appeals concluded the record provided reason to believe Black’s mental condition would be a significant factor, and that the existing materials did not satisfy the § 19-2522(3) requirements; it vacated the sentence and remanded for a § 19-2522 evaluation and resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused its discretion by denying a § 19-2522 psychological evaluation before sentencing	State: court properly denied; need not consider pro se filing; existing records (§ 19-2524 report, GAIN, PSI) were sufficient or court acted within discretion	Black: long history of serious mental illness, screening and family letters support that mental condition would be a significant factor at sentencing; evaluation necessary	The court abused its discretion. The record supported reason to believe mental condition would be a significant sentencing factor and the existing materials did not meet § 19-2522(3) requirements; remand for evaluation and resentencing.
Whether Black’s five-year determinate sentence was excessive	State: sentence appropriate (implicit)	Black: sentence excessive	Not reached on the merits. Sentence vacated pending evaluation and resentencing.

State v. Coonts, 137 Idaho 150, 44 P.3d 1205 (Ct. App. 2002) (sets standard for when a defendant’s known mental illness should trigger a § 19-2522 evaluation)
State v. Durham, 146 Idaho 364, 195 P.3d 723 (Ct. App. 2008) (court may deny evaluation if record already meets § 19-2522(3) requirements)
State v. Hanson, 152 Idaho 314, 271 P.3d 712 (2012) (long history of serious mental illness makes mental condition a significant sentencing factor)
State v. Schultz, 149 Idaho 285, 233 P.3d 732 (Ct. App. 2010) (milder mental disorders and drug-related issues may be insufficient to require a § 19-2522 evaluation)
State v. Adams, 137 Idaho 275, 47 P.3d 778 (Ct. App. 2002) (family statements alone may be insufficient to establish significance of mental condition)
State v. McFarland, 125 Idaho 876, 876 P.2d 158 (Ct. App. 1994) (a cursory psychological report may fail to satisfy § 19-2522(3))
State v. Pearson, 108 Idaho 889, 702 P.2d 927 (Ct. App. 1985) (psychological reports lacking in-depth analysis may be insufficient under § 19-2522(3))