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Due process as expressed in the Constitutions of the United States and of Idaho does not constitutionally mandate an insanity defense and Idaho Code § 18-207 does not deprive defendants of their due process rights under the state or federal Constitution.
Defendant Barry Searcy killed Teresa Rice while robbing Jack’s Grocery Store in Ashton, Idaho. At trial a jury found defendant guilty of murder in the first degree by finding both premeditation and by finding that defendant killed while committing a robbery. Defendant was also found guilty of robbery and of using a firearm while committing a felony. Over objection, the trial judge at sentencing admitted a victim impact statement from Rice's family. Michael Rice, the victim's husband, indicated in the statement that he favored imposition of the death penalty for defendant and that he felt it should be swiftly carried out. Nevertheless, the trial judge did not impose the death penalty on the defendant, and instead, imposed a life sentence with enhancement of ten years. Defendant appealed from the conviction and sentences, arguing that I.C. § 18-207 unconstitutionally denied him due process of law because it prevented him from pleading insanity as a defense. Defendant also alleged that the trial court erred by denying his motion to strike a victim impact statement which was allegedly used as a basis for arriving at the sentence. Moreover, defendant argued that the trial court imposed an invalid sentence when it gave a ten-year enhancement both to the determinate life sentence without possibility of parole for the premeditated first-degree murder, and a ten-year enhancement to the consecutive indeterminate life sentence imposed for the crime of robbery. As a result, defendant argued that he should have been present when the trial court corrected the sentence.
The court affirmed defendant's conviction, finding that neither the federal nor the state constitutions contained any language setting forth any such to present an insanity defense as defendant argued. The court rejected the claim that the disallowance of the insanity defense under Idaho Code § 18-207 deprived defendant of one of the fundamental principles of liberty and justice that were at the base of all civil and political institutions and thus denied him due process of law. Further, the court ruled that the trial court did not err by denying defendant's motion to strike a victim impact statement which was allegedly used as a basis for arriving at the sentence. The court did however vacate and remand the sentence imposed upon defendant in his absence in violation of Idaho Crim. R. 43(a).