State v. Randy C. Eiland
Background
- In October 2014 an intruder used bear spray to force entry into a family home; victims retreated and the intruder fled. Police later arrested Randy Eiland nearby; officers smelled bear spray on him and found an envelope, gloves, and other items consistent with the attack. Glass shards found on Eiland were forensically linked to the broken back door.
- The State charged Eiland with battery with intent to commit a serious felony, burglary, and persistent violator; trial was set and reset multiple times during 2015.
- Eiland, proceeding pro se with standby counsel, requested and received conditional funding for investigative services and for two experts (William Schneck and Dr. Daniel Reisberg), contingent on showing each expert was available and willing to testify the week of trial.
- The court granted three continuances but warned it would not grant further continuances absent extraordinary circumstances. Eiland filed a fourth continuance because motions and outstanding forensic/expert work remained; the State objected.
- At the pretrial hearing Eiland said he lacked funds (phone minutes) to contact Reisberg to secure his willingness/availability. The court found Eiland had two months between the conditional funding order and running out of phone funds and had not shown Reisberg’s availability; the court denied the fourth continuance.
- Trial proceeded; the jury convicted Eiland of battery with intent to commit a serious felony and burglary, and the district court found him a persistent violator. Eiland appealed, arguing denial of the continuance deprived him of expert assistance and violated due process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denying the 4th continuance violated due process by depriving Eiland of expert assistance | State: court did not abuse discretion; it conditionally provided funds and Eiland failed to secure the expert | Eiland: conditional funding meant the court found expert necessary and denial prevented his reliance on Reisberg, violating right to fair trial | Court: No abuse of discretion; conditional funding was provided but Eiland failed to show expert’s availability/willingness and was not denied access to basic defense tools |
| Whether conditional authorization of funds equals court’s finding that a particular expert is necessary | State: funding authorization is conditional and does not guarantee retention of a specific expert | Eiland: asserts conditional authorization established necessity of that specific expert | Court: District court authorizes funds when expert services may be necessary, but that does not mean retention of any particular expert is guaranteed without showing availability/willingness |
| Whether lack of phone funds excused failure to secure expert | State: Eiland had ample time (about two months) to contact expert before funds were exhausted | Eiland: inability to add phone minutes prevented contacting expert | Court: Trial court reasonably concluded two months sufficed and Eiland did not demonstrate inability to contact Reisberg |
| Whether denial of continuance prejudiced Eiland’s substantial rights | State: no prejudice—Eiland had access to expert funding and other preparation; delay would prejudice State | Eiland: denial prevented expert testimony and impaired defense | Court: No prejudice shown; denial was within discretion and did not violate due process |
Key Cases Cited
- State v. Ransom, 124 Idaho 703 (discretion to grant continuance rests with trial court)
- State v. Hedger, 115 Idaho 598 (appellate review of trial court discretion requires multi-tiered inquiry)
- State v. Cagle, 126 Idaho 794 (denial of continuance not an abuse absent prejudice to substantial rights)
- State v. Schaffer, 133 Idaho 126 (use federal due process analysis when state/federal claim unclear)
- State v. Olin, 103 Idaho 391 (state not required to provide expert merely on request; denial of basic tools of defense violates due process)
- Ake v. Oklahoma, 470 U.S. 68 (indigent defendant entitlement to psychiatric expert when necessary for fair trial)
- State v. Dunlap, 155 Idaho 345 (court must determine necessity of funds for indigent defense services in interest of justice)
- State v. Lovelace, 140 Idaho 53 (requests for expert/investigative services measured by fundamental fairness standard)