State v. Rhonda Trusdall
155 Idaho 965
| Idaho Ct. App. | 2014Background
- Trusdall operated a Polaris Ranger UTV in a church parking lot with six children not wearing helmets.
- An officer smelled alcohol, observed a half-empty beer, and noted intoxication after field sobriety tests.
- Breath tests showed BAC of .169 and .164; she was charged with DUI, open-container transport, etc.
- Trusdall moved to dismiss DUI on grounds the UTV isn’t a motor vehicle under I.C. 18-8004 and the UTV-specific statute (I.C. 67-7114) barred or preempted the general DUI statute.
- The magistrate denied the motion; the State added charges and Trusdall entered a conditional guilty plea to DUI and open container; other charges were dismissed.
- The district court reversed, remanding to withdraw pleas and dismiss charges; the State appealed, and the Court of Appeals reversed the district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a UTV qualifies as a motor vehicle under I.C. 18-8004. | Trusdall: UTV not a motor vehicle; DUI statute doesn’t apply. | State: UTV is a motor vehicle; plain language and harmony with the UTV statute. | UTV is a motor vehicle under I.C. 18-8004; general DUI statute applies. |
| Whether I.C. 18-8004 and I.C. 67-7114 are harmonious or conflicting. | Trusdall: UTV-specific statute controls; precludes general DUI charge. | State: statutes harmonize; both apply depending on vehicle type and circumstances. | Statutes are harmonious; the State may charge under the general DUI statute apart from the UTV-specific statute. |
Key Cases Cited
- State v. Barnes, 133 Idaho 378 (1999) (snowmobile DUI vs. general DUI statutes harmonized; self-propelled vehicles)
- State v. Reyes, 139 Idaho 502 (2003) (statutory construction; plain language review; in pari materia context)
- Bailey v. Bailey, 153 Idaho 526 (2012) (appellate standard; record review on appeal from district court)
- Pelayo v. Pelayo, 154 Idaho 855 (2013) (standard of review for appellate review of magistrate findings)
- State v. Korn, 148 Idaho 413 (2009) (procedural binding on appellate review; affirm/reverse framework)
- State v. Burnight, 132 Idaho 654 (1999) (statutory interpretation where language is plain and unambiguous)