Joel Guerrero v. State of Idaho

Idaho Court of Appeals·Decided August 17, 2026·No. 52658·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 52658

JOEL GUERRERO, )

) Filed: August 17, 2026 Petitioner-Appellant, )

) Melanie Gagnepain, Clerk v. )

) THIS IS AN UNPUBLISHED STATE OF IDAHO, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Respondent. )

)

Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada County. Hon. Jason D. Scott, District Judge.

Judgment summarily dismissing petition for post-conviction relief, affirmed.

Waldron Legal, PLLC; Maya P. Waldron, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; T. Michael MacEgan, Deputy Attorney General, Boise, for respondent.

TRIBE, Chief Judge Joel Guerrero appeals from the district court’s judgment summarily dismissing his petition for post-conviction relief. We affirm.

I.

FACTUAL AND PROCEDURAL BACKGROUND Guerrero pled guilty to rape, Idaho Code § 18-6101. In exchange for his guilty plea, the State agreed to dismiss the remaining charges in this case and dismiss another case in its entirety.1 Before entering his guilty plea, Guerrero completed a guilty plea advisory form acknowledging that the maximum sentence was life imprisonment and that no one promised him a particular sentence. During the change of plea hearing, the trial court similarly advised Guerrero

1 According to the plea agreement, the State dismissed the following: the repeat sexual offender enhancement; forcible penetration by use of a foreign object; kidnapping in the first degree; and a separate case of five counts of video voyeurism.

that the maximum possible penalty was life imprisonment and confirmed that Guerrero understood it retained the authority to impose any lawful sentence, notwithstanding the State’s recommendation. The trial court also asked Guerrero if anyone told him the trial court would “go easy” on him if he pled guilty. Guerrero answered, “No, sir.” Guerrero further acknowledged that no one promised him anything beyond the State’s promises in the plea agreement. The trial court later sentenced Guerrero to life imprisonment without the possibility of parole. Guerrero filed an Idaho Criminal Rule 35 motion for reduction of sentence, which the trial court denied. Guerrero appealed, and this Court affirmed his sentence and the denial of his I.C.R. 35 motion in an unpublished opinion.2 Guerrero filed a petition for post-conviction relief, asserting trial counsel rendered ineffective assistance during plea negotiations. Guerrero specifically alleged trial counsel advised Guerrero that, “at worst,” he would receive a twenty-year determinate sentence before becoming eligible for parole and failed to advise him that he could receive a sentence of life imprisonment without the possibility of parole. Guerrero asserted that, had he known such a sentence was possible, he would have insisted on going to trial. In support of his petition, Guerrero submitted his own declaration and a declaration from his sister. In her declaration, Guerrero’s sister similarly stated she understood from conversations with trial counsel that Guerrero would be eligible for parole after approximately fifteen years.

The State answered Guerrero’s petition and filed a motion for summary dismissal, arguing that his ineffective assistance of trial counsel claim was disproved by the record of the underlying criminal proceedings and unsupported by admissible evidence sufficient to establish a genuine issue of material fact. At the summary dismissal hearing, the district court orally granted the State’s motion and determined that Guerrero’s ineffective assistance of trial counsel claim was disproved by the record of the underlying criminal case. The district court later entered a written order further explaining its reasoning and dismissed Guerrero’s petition for post-conviction relief. Guerrero appeals.

2 See State v. Guerrero, Docket No. 49591 (Ct. App. June 28, 2023).

II.

STANDARD OF REVIEW

On appeal from an order of summary dismissal, we apply the same standards utilized by the trial courts and examine whether the petitioner’s admissible evidence asserts facts which, if true, would entitle the petitioner to relief. Ridgley v. State, 148 Idaho 671, 675, 227 P.3d 925, 929 (2010); Sheahan v. State, 146 Idaho 101, 104, 190 P.3d 920, 923 (Ct. App. 2008). Over questions of law, we exercise free review. Rhoades v. State, 148 Idaho 247, 250, 220 P.3d 1066, 1069 (2009); Downing v. State, 136 Idaho 367, 370, 33 P.3d 841, 844 (Ct. App. 2001).

III.

ANALYSIS

Guerrero argues the district court erred in summarily dismissing his claim because nothing in the record rebutted the allegation in his post-conviction petition that he was never advised, and did not understand, that he could be sentenced to a fixed life sentence if he pled guilty. Guerrero contends the district court improperly discounted his allegation based on what the trial court believed Guerrero should have understood from the plea proceedings. Guerrero further asserts that, because the district court did not address prejudice, this Court should decline to do so on appeal, but if it does, he sufficiently alleged prejudice by asserting that, had he known a fixed life sentence was possible, he would have rejected the plea agreement and insisted on going to trial and that the plea colloquy did not cure trial counsel’s deficient advice. The State responds that Guerrero’s claim is disproved by the record of the underlying criminal proceedings and unsupported by admissible evidence sufficient to establish a genuine issue of material fact. The State further responds that Guerrero failed to establish prejudice because his allegation was insufficient to show he would have rejected the plea agreement and, in any event, the trial court’s plea colloquy cured any prejudice resulting from trial counsel’s alleged deficient advice.

A petition for post-conviction relief initiates a proceeding that is civil in nature. I.C.

§ 19-4907; Rhoades, 148 Idaho at 249, 220 P.3d at 1068; State v. Bearshield, 104 Idaho 676, 678, 662 P.2d 548, 550 (1983); Murray v. State, 121 Idaho 918, 921, 828 P.2d 1323, 1326 (Ct. App. 1992). Like a plaintiff in a civil action, the petitioner must prove by a preponderance of evidence the allegations upon which the request for post-conviction relief is based. Goodwin v. State, 138 Idaho 269, 271, 61 P.3d 626, 628 (Ct. App. 2002). A petition for post-conviction relief differs

from a complaint in an ordinary civil action. Dunlap v. State, 141 Idaho 50, 56, 106 P.3d 376, 382 (2004). A petition must contain much more than a short and plain statement of the claim that would suffice for a complaint under Idaho Rule of Civil Procedure 8(a)(1). Rather, a petition for post-conviction relief must be verified with respect to facts within the personal knowledge of the petitioner, and affidavits, records, or other evidence supporting its allegations must be attached or the petition must state why such supporting evidence is not included with the petition. I.C. § 19-4903. In other words, the petition must present or be accompanied by admissible evidence supporting its allegations or the petition will be subject to dismissal. Wolf v. State, 152 Idaho 64, 67, 266 P.3d 1169, 1172 (Ct. App. 2011).

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