State v. LDonna Marie Youmans, 161 Idaho 4

Youmans, a former visiting nurse, was captured on surveillance entering multiple apartments at a retirement facility during lunch hours; residents later reported missing prescription medications.
Police arrested Youmans and found seventeen loose pills in her purse; Detective Paporello identified them at trial as hydrocodone after using an unnamed online pill-identification database.
A jury convicted Youmans of burglary, attempted burglary, and misdemeanor possession of a controlled substance; the court imposed concurrent unified sentences and retained jurisdiction before ultimately suspending and placing her on probation.
Youmans timely appealed and raised, among other claims, that the State withheld the computer hard drive containing surveillance footage and challenged the admissibility and sufficiency of the pill-identification testimony.
After the notice of appeal, the State sought to supplement the district-court record with affidavits and evidence showing efforts to make the hard drive available; the district court admitted that material and made factual findings adverse to Youmans.
On appeal, the Court of Appeals affirmed the convictions and sentences, held the pill-identification testimony and the circumstantial evidence sufficient to support the drug-possession conviction, but vacated the district court’s post-appeal order and struck the supplemental filings for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of detective’s pill-identification testimony	Testimony was proper lay-opinion based on officer’s perception and common field practice	Testimony lacked proper foundation and required expert/scientific proof	Admitted as lay opinion under I.R.E. 701; adequate foundation; not expert testimony
Sufficiency of evidence of controlled substance	Circumstantial evidence and officer’s identification permitted a reasonable jury to find hydrocodone	Pills were never chemically analyzed; identification unreliable without lab testing	Evidence sufficient; chemical analysis preferred but not required; circumstantial proof can suffice
Excessiveness of sentence	State: sentence justified to protect public given offenses and criminal history	Youmans: withheld judgment or lesser sentence warranted given lack of prior felonies and treatment prospects	Sentence not an abuse of discretion; focused on protecting society and deterrence
District court jurisdiction to supplement record after appeal filed	State: allowed to create full record to refute alleged withholding of evidence	Youmans: court lost jurisdiction after timely notice of appeal; post-appeal factual findings improper	Court lacked jurisdiction to take evidence/make findings after notice of appeal; order to supplement vacated and post-appeal filings struck

State v. Gilpin, 132 Idaho 643 (Ct. App. 1999) (trial court’s admission of evidence reviewed for abuse of discretion)
State v. Zimmerman, 121 Idaho 971 (1991) (appellate review standard for evidentiary rulings)
State v. Hedger, 115 Idaho 598 (1989) (multi-tiered inquiry for discretionary decisions)
State v. Mitchell, 130 Idaho 134 (Ct. App. 1997) (identity of controlled substance may be proved circumstantially without chemical analysis)
State v. Wade, 125 Idaho 522 (Ct. App. 1993) (I.A.R. 13(c)(10) does not permit post-appeal reconsideration or post hoc rationalizations)
State v. Wilson, 136 Idaho 771 (Ct. App. 2001) (trial court limited to rulings on motions pending at time of appeal)
State v. Barnes, 147 Idaho 587 (Ct. App. 2009) (lay witness identification admissible using totality of circumstances)
State v. Oliver, 144 Idaho 722 (2008) (appellate independent review of sentence considering offense, offender, public protection)
State v. Manzanares, 152 Idaho 410 (2012) (mootness doctrine and justiciable controversies)
State v. Barclay, 149 Idaho 6 (2010) (exceptions to mootness doctrine)