State v. Reid
151 Idaho 80
Idaho Ct. App.2011Background
- Reid aided and abetted in two first-degree murders at a Dobson Pass campsite; co-defendant Kienholz shot Howard and Bewick; Reid helped plan and facilitate the murders and disposed of evidence.
- Reid overheard plans to go to Bolivia for illicit work; group used Howard’s car and acquired a pistol; Reid joined with Purtill in the truck.”
- Reid participated in obtaining shells, retrieving a pistol, and encouraging Kienholz to shoot; after killings, Reid discarded shells and joined the others in Boise.
- Witnesses Kienholz and Wilson testified against Reid; photographs of the crime scene were admitted after in limine rulings; the State introduced a Rollins interview at sentencing.
- Reid challenged jury instructions on aiding and abetting and alleged a missing requirement of shared premeditation; he challenged admission of three gruesome photographs; he argued Rollins transcript should not affect sentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did jury instructions require shared premeditation? | Reid asserts plain error for omitting premeditationSharing. | State says instructions correctly stated law and shared intent was included. | No plain error; instructions adequately conveyed shared criminal intent. |
| Were Exhibits 17, 22, 27 admissible under I.R.E. 403? | Photos were unnecessarily prejudicial and minimally relevant. | Photos aided understanding of corpus delicti, injuries, and time of death. | Photographs admissible; district court did not abuse discretion; probative value outweighed prejudice. |
| Was sentencing due process violated by considering Rollins transcript? | Rollins interview was unreliable hearsay; should not influence sentencing. | Court can consider broad information; Rollins provided corroborating details. | No due process violation; information not materially untrue and credibility issues addressed. |
Key Cases Cited
- State v. Hickman, 146 Idaho 178, 191 P.3d 1098 (Idaho Ct. App. 2008) (instructions must fairly present issues and law)
- State v. Cuevas-Hernandez, 140 Idaho 373, 93 P.3d 704 (Idaho Ct. App. 2004) (pattern ICJI instructions presumptively correct)
- State v. Ruel, 141 Idaho 600, 114 P.3d 158 (Idaho Ct. App. 2005) (pattern jury instructions; use unless better fit exists)
- Old Chief v. United States, 519 U.S. 172 (U.S. 1997) (prosecutor need not accept stipulations; evidence has narrative force)
- State v. Enno, 119 Idaho 392, 807 P.2d 610 (Idaho Ct. App. 1991) (graphic photos in murder cases upheld after balancing)