Idaho v. GlodowskiAnnotate this Case
David Glodowski appealed after he was convicted for failing to update his sex-offender registration in violation of Idaho Code section 18-8309. He argued the district court erred by ruling that his prior conviction under a Wisconsin statute was “substantially equivalent” to Idaho statutes that required sex-offender registration in Idaho. After review, the Idaho Supreme Court determined the district court improperly allowed the State to seek a redetermination of the “substantially equivalent” element given that the Idaho Bureau of Criminal Identification made a final determination on that element. However, because the State put forth sufficient evidence to prove that element, and the district court’s jury instruction accomplished the same purpose, the Supreme Court concluded the error was harmless. Accordingly, the Court found no reversible error in the district court’s decision to grant the State’s motion and provide the jury instruction. Therefore, judgment of conviction was affirmed.