408 P.3d 474
Idaho2017Background
- In 2006, when he was 16, Torey Michael Adamcik and co-defendant Brian Draper planned and murdered Cassie Stoddart; video recorded planning and post-crime statements and evidence was recovered from a Black Rock Canyon (BRC) site.
- At trial, forensic testimony established multiple stab wounds; State experts concluded at least two knives were used and some wounds were potentially fatal.
- A jury convicted Adamcik of conspiracy to commit first-degree murder and first-degree murder; he received a fixed life sentence and an indeterminate life term; convictions and sentences were affirmed on direct appeal.
- In post-conviction proceedings Adamcik raised seven claims: Brady, several ineffective-assistance-of-counsel (IAC) claims (failure to test knives, failure to challenge search warrant, failure to exclude invocation-of-counsel video, cumulative prejudice, failure to inform of plea), and an Eighth Amendment challenge to his fixed life sentence under Miller/Montgomery.
- The district court dismissed some claims on summary disposition, held an evidentiary hearing on the remaining IAC claims, denied relief, and denied reconsideration under Montgomery. Adamcik appealed; the Idaho Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument (Adamcik) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1) Failure to move to suppress computer evidence (warrant omission) | Omission of “computer” from warrant command invalidated seizure; counsel deficient for not moving; evidence prejudiced character proof. | Magistrate intended affidavit language; omission was clerical/scrivener error; affidavit was incorporated; suppression would not be required and evidence was not outcome-determinative. | Court: omission was a scrivener’s error and affidavit accompanied warrant; motion to suppress would not have succeeded, so counsel not deficient. |
| 2) Failure to obtain/test actual murder knives and admit expert testing | Counsel’s failure to secure/testing the actual knives prevented favorable expert testimony that only one knife was used; prejudiced defense. | Defense could not show the proffered testing would have produced a reasonable probability of a different verdict; jury had ample contrary evidence; any counsel chastisement did not undermine outcome. | Court: counsel’s failure was deficient on this point, but no prejudice shown—additional testing/testimony would likely not have changed verdict. |
| 3) Cumulative prejudice from multiple alleged errors (including showing invocation-of-counsel video) | Even if individual errors were harmless, combined they undermined confidence in outcome. | The invocation clip added little compared to other admissions and overwhelming evidence; cumulative errors did not create reasonable probability of different result. | Court: cumulative effect did not meet Strickland prejudice requirement; relief denied. |
| 4) Eighth Amendment challenge to fixed-life juvenile sentence under Miller/Montgomery | Sentencing court failed to adequately consider youth and attendant characteristics; fixed life sentence therefore unconstitutional for juvenile. | Sentencing judge considered psychological testimony and youth; concluded crime showed lack of transient immaturity and risk to reoffend; Miller/Montgomery do not require specific talismanic language. | Court: sentencing record shows youth and attendant characteristics were considered; sentence did not violate Eighth Amendment or Idaho Constitution. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance two‑prong test)
- Miller v. Alabama, 567 U.S. 460 (mandatory juvenile LWOP unconstitutional; must consider youth)
- Montgomery v. Louisiana, 136 S. Ct. 718 (Miller retroactive; sentencing courts must consider youth)
- Wurdemann v. State, 161 Idaho 713 (Idaho standard for evaluating failure to file suppression motion)
- State v. Adamcik, 152 Idaho 445 (direct appeal—sufficiency of evidence re: multiple knives)
- Johnson v. State, 162 Idaho 213 (Idaho treatment of Miller/Montgomery in sentencing review)
- Groh v. Ramirez, 540 U.S. 551 (warrant may incorporate affidavit if appropriate words used)
- Cullen v. Pinholster, 563 U.S. 170 (definition of reasonable probability under Strickland)
- Harrington v. Richter, 562 U.S. 86 (likelihood of different result must be substantial)
- United States v. Ventresca, 380 U.S. 102 (practical approach to Fourth Amendment particularity)