State v. Richard W. Wright, 295 P.3d 1016

Wright was charged with leaving the scene of a property-damage crash under I.C. § 49-1301(1) after an ice-related single-vehicle incident damaged a traffic sign and his vehicle, which he then drove away with.
Two witnesses followed Wright, obtained his license plate, and alerted police; Wright later acknowledged by phone that he was involved and intended to report the accident.
When police visited his workplace, Wright denied involvement, stating another person drove his vehicle.
The district court convicted Wright at a bench trial; on intermediate appeal, the district court affirmed the conviction.
The issue on appeal was whether the State presented sufficient evidence to prove Wright violated § 49-1301(1).
This appeal requires interpretation of § 49-1301(1) to determine whether it covers single-vehicle accidents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 49-1301(1) apply to single-vehicle accidents?	State contends the statute covers accidents where the driver’s own vehicle is damaged.	Wright argues the statute applies only to accidents involving another attended vehicle.	§ 49-1301(1) applies only to accidents involving a second attended vehicle.

State v. Bettwieser, 143 Idaho 582 (Ct. App. 2006) (sufficiency of evidence review in criminal appeals)
State v. Smith, 139 Idaho 295 (Ct. App. 2003) (standard for reviewing sufficiency of evidence)
Losser v. Bradstreet, 145 Idaho 670 (2008) (substantial evidence standard on district court findings)
State v. DeWitt, 145 Idaho 709 (Ct. App. 2008) (appellate review of sufficiency of evidence in criminal cases)
Aguilar v. Coonrod, 151 Idaho 642 (Ct. App. 2011) (statutory interpretation standard)
State v. Reyes, 139 Idaho 502 (Ct. App. 2003) (statutory interpretation and plain meaning)
State v. Hart, 25 P.3d 850 (2001) (statutory construction principles)
State v. Burnight, 132 Idaho 654 (1999) (interpretation of criminal statutes)
State v. Escobar, 134 Idaho 387 (Ct. App. 2000) (avoid absurd results in statutory construction)
State v. Beard, 135 Idaho 641 (Ct. App. 2001) (consideration of legislative intent in ambiguous statutes)