State of Idaho v. Bryon E. Prather, 135 Idaho 770

Summary

The Idaho Supreme Court affirmed Bryon E. Prather's conviction under Idaho Code § 18-918(3) for felony domestic violence involving a traumatic injury. The court held that the statute was not unconstitutionally vague because it provided adequate notice and could be applied constitutionally in at least some circumstances. The court also rejected the claim that the statute improperly shifted the prosecution's burden of proof to the defense.

Holdings

1. Idaho Code section 18-918(3) is not unconstitutionally vague because, read with the statutory definitions of household member, traumatic injury, and battery, it gives adequate notice of prohibited conduct and provides sufficient guidance to distinguish felony domestic violence from misdemeanor domestic battery.
2. Idaho Code section 18-918 does not violate due process by shifting the burden of proof to the defense because the prosecution must prove every element of felony domestic violence, including that the defendant willfully inflicted a traumatic injury.
3. Idaho Code section 18-918(3) requires willful conduct and incorporates the criminal-intent requirement applicable under Idaho law; it is not a strict-liability offense absent a clear legislative indication to that effect.

Questions Presented

1. Whether Idaho Code section 18-918(3), defining felony domestic violence as willfully inflicting a traumatic injury on a household member, is unconstitutionally vague.
2. Whether Idaho Code section 18-918 impermissibly shifts the prosecution's burden of proof to the defense by requiring the defense to establish the absence of a traumatic injury for a misdemeanor conviction.

Disposition

affirmed