State v. Schiermeier, 447 P.3d 895

Chad Schiermeier, a Blaine County deputy and long-time manager/director of DARE/PAL (a §501(c)(3) youth program), was an authorized user of the nonprofit’s bank account and effectively ran the program alone from ~2009–2015.
Bank records and an ISP investigation showed numerous ATM cash withdrawals (totaling tens of thousands per year) and purchases of high-end outdoor and hunting gear from 2009–2015; some items were used on out-of-state hunting trips and for Schiermeier’s outfitting business.
DARE/PAL’s advertised activities did not include hunting/archery; witnesses and program materials supported that many purchased items were not program-related. Treasurer/accountant testimony showed required receipts and records were missing.
The State charged Schiermeier with one count of grand theft (I.C. §§ 18-2403, 18-2407, 18-2408) for wrongfully taking or exercising unauthorized control over DARE/PAL funds (2009–2015). He was convicted after a jury trial.
At sentencing the court imposed a unified 14‑year term with 6 years fixed and ordered restitution of $86,868.03; Schiermeier appealed, arguing insufficient evidence on the “wrongful/unauthorized” element and that the sentence was excessive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Schiermeier’s taking was "wrongful" or "unauthorized"	The purchases and undocumented cash withdrawals showed use of nonprofit funds for personal purposes, permitting a reasonable inference of wrongful/unauthorized taking	State needed to prove the funds were used exclusively for non-DARE/PAL purposes; occasional program use of items could legitimize purchases	Affirmed — viewing evidence in prosecution’s favor, a rational jury could find wrongful/unauthorized taking beyond a reasonable doubt
Whether the 14-year (6 years fixed) sentence was an abuse of discretion/excessive	Sentence necessary to protect public, deter, punish, and reflect seriousness and harm to community program and trust	Mitigating factors (first offender, remorse, community service/support) warranted probation, retained jurisdiction, or lesser term	Affirmed — sentence within statutory limits and not unduly harsh given court’s consideration of aggravating/mitigating factors and objectives of sentencing

State v. Tryon, 164 Idaho 254 (discussing sufficiency of evidence standard for jury verdicts)
State v. Eliasen, 158 Idaho 542 (explaining appellate review—view evidence in light most favorable to prosecution)
State v. Adamcik, 152 Idaho 445 (deference to jury on credibility and inferences)
State v. Kralovec, 161 Idaho 569 (standard for upholding jury convictions)
State v. Sheahan, 139 Idaho 267 (sentencing abuse of discretion and standards)
State v. Zichko, 129 Idaho 259 (when jury instruction definitions are unnecessary for commonly understood terms)
State v. Hansen, 138 Idaho 791 (fixed term considered for appellate sentencing review)
State v. Toohill, 103 Idaho 565 (sentencing objectives: protection, deterrence, rehabilitation, retribution)