State v. Adkins

Summary

The Idaho Supreme Court held that, in a prosecution for concealment of evidence under Idaho Code section 18-2603, the jury determines the underlying investigation or offense, but the court determines as a matter of law whether that offense is a felony. The court overruled contrary portions of State v. Yermola, affirmed Kathryn Dianne Adkins's conviction, vacated her sentence as exceeding the statutory maximum, and remanded for entry of a corrected sentence.

Holdings

1. In a prosecution for felony concealment of evidence under Idaho Code section 18-2603, the jury must determine the offense that was the subject of the relevant investigation, but whether that offense is legally classified as a felony is a question of law for the court.
2. The evidence was sufficient to support Adkins's conviction because the jury found the required adjudicative facts concerning her willful concealment, knowledge, and intent to prevent discovery of evidence in an investigation involving possession of methamphetamine, and the felony classification of that offense was a matter of law.
3. The six-year indeterminate sentence for felony concealment of evidence was illegal because Idaho Code section 18-2603 authorizes a maximum of five years of imprisonment and a ten-thousand-dollar fine.

Questions Presented

1. Whether the felony status of the offense underlying a charge of felony concealment of evidence is an adjudicative fact that must be submitted to and found by the jury.
2. Whether the evidence was insufficient to support Adkins's felony concealment-of-evidence conviction because the State did not present evidence establishing that possession of methamphetamine is a felony.
3. Whether Adkins's six-year indeterminate sentence for felony concealment of evidence exceeded the statutory maximum and was therefore illegal.

Disposition

reversed_and_remanded