Zane Jack Fields v. State of Idaho
298 P.3d 241
Idaho2013Background
- Fields is serving a death sentence for first-degree murder of Mary Vanderford; the orange camouflage coat (Defense Exhibit 22) was used to identify him at trial.
- The coat was destroyed in July 2004 by the Boise Police Department Crime Lab, contrary to a court order to preserve it.
- Fields’s fifth post-conviction petition was filed October 12, 2010, alleging the coat’s destruction was new evidence proving innocence and Violating due Process.
- The district court dismissed the petition as untimely under I.C. § 19-2719(3) and (5)(b) for a successive petition, and upon the facts found, there was no genuine issue about the destruction’s relevance.
- Fields had previously pursued four earlier post-conviction proceedings (Fields I–IV), with prior petitions denied or resolved before this fifth petition.
- On appeal, the Idaho Supreme Court affirmed the district court’s dismissal, holding the petition untimely under the capital-case time limits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of the fifth petition under 19-2719 | Fields argues the coat’s destruction was not reasonably knowable earlier. | State contends destruction was known or reasonably should have been known earlier. | Untimely under 19-2719(3) and (5)(b). |
| Whether destruction of the coat constitutes new evidence within 42-day rule | Fields contends destruction is new, post-42-day evidence. | State argues evidence is impeaching or cumulative, not new. | Not new; knowledge occurred over six years after destruction; petition untimely. |
| Proper disposition based on timeliness versus merits | If timely, merits could require relief. | Timeliness bar precludes consideration on merits. | District court’s dismissal affirmed on timeliness grounds. |
Key Cases Cited
- Fields v. State, 127 Idaho 904, 908 P.2d 1211 (1995), 127 Idaho 904 (Idaho 1995) (initial death-penalty conviction affirmed; coat evidence used at trial)
- Fields v. State, 135 Idaho 286, 17 P.3d 230 (2000), 135 Idaho 286 (Idaho 2000) (Fields II; summary dismissal of second post-conviction relief appeal)
- Fields v. State, 149 Idaho 399, 234 P.3d 723 (2010), 149 Idaho 399 (Idaho 2010) (Fields III; Ring v. Arizona retroactivity denied at petition stage)
- Fields v. State, 151 Idaho 18, 253 P.3d 692 (2011), 151 Idaho 18 (Idaho 2011) (Fields IV; denial affirmed regarding DNA/fingerprint testing requests)
- Pizzuto v. State, 134 Idaho 793, 10 P.3d 742 (Idaho 2000) (timeliness and standard for successive post-conviction petitions in Idaho capital cases)