Idaho v. Ogden
Annotate this CaseDarin Ogden appealed his conviction for possession of methamphetamine and drug paraphernalia. During a consensual encounter, officers searched Ogden’s vehicle outside of a business and arrested Ogden for felony possession. At trial, the State introduced redacted police officer on-body video showing the search. The nature and scope of the video became an issue during trial. The jury found Ogden guilty on both counts. At sentencing, Ogden objected to portions of a presentence investigation (PSI) report that included investigative and third-party records from two pending unrelated cases, and seven allegedly inaccurate statements in the PSI. Ogden’s objections to the PSI were largely denied. Ogden appealed to the Court of Appeals, which affirmed, and he then petitioned for review by the Idaho Supreme Court, arguing: (1) a response he gave to officers that was recorded on the video, but redacted, should have been admitted; and (2) it was error for the district court to permit irrelevant evidence to be presented to the jury. Given the accumulation of these alleged multiple errors, Ogden argued that his conviction had to be vacated. The Supreme Court determined district court erred by allowing the State to present evidence that the district court determined was not relevant, but that this error was harmless. "A single error does not require Ogden’s conviction to be vacated." Further, the Supreme Court found the district court abused its discretion in failing to redline the portions of the PSI it had agreed to correct, but did not abuse its discretion in declining to redline portions describing conduct Ogden was acquitted of. The case was remanded to district court to ensure that the victim’s medical records were stricken from the PSI.
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