State v. Borek

CourtIdaho Supreme Court
DecidedFebruary 4, 2026
Docket51548
StatusPublished

This text of State v. Borek (State v. Borek) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Borek, (Idaho 2026).

Opinion

IN THE SUPREME COURT OF THE STATE OF IDAHO

Docket No. 51548-2024

STATE OF IDAHO, ) ) Plaintiff-Appellant, ) Boise, September 2025 Term ) v. ) Opinion filed: February 4, 2026 ) LEWIS VANALEN BOREK, ) Melanie Gagnepain, Clerk ) Defendant-Respondent. ) )

Appeal from the District Court of the Fourth Judicial District of the State of Idaho, Ada County. Derrick J. O’Neill District Judge.

The decision of the district court is reversed.

Raúl R. Labrador, Idaho Attorney General, Boise, for Appellant. Kale D. Gans argued.

Erik R. Lehtinen, State Appellate Public Defender, Boise, for Respondent. Andrea W. Reynolds argued.

ZAHN, Justice. The State of Idaho appeals from the district court’s order granting Lewis Vanalen Borek’s motion in limine. Borek was arrested and charged with driving under the influence. In advance of trial, Borek filed a motion in limine to preclude the State from introducing records the State obtained, including records from the Idaho Prescription Monitoring Program, Ada County Jail, and Star Pharmacy. The records included information about prescription drug orders for mental health medications that medical providers issued to Borek as well as the dates and locations where Borek filled the prescriptions. Borek argued the records were inadmissible under Idaho Rule of Evidence 503(b)(2), Idaho’s psychotherapist-patient privilege. The district court granted Borek’s motion and concluded the records constituted confidential communications and were therefore privileged under Rule 503. The district court also determined that statements Borek made to arresting officers at the scene, indicating that he was taking anti-depressant medication, did not waive the privilege because those statements also constituted confidential communications under the rule. The State filed a motion for permissive appeal, which this Court granted. For the reasons discussed below, we reverse the district court’s decision. I. FACTUAL AND PROCEDURAL BACKGROUND On January 17, 2020, Borek rear-ended another vehicle while driving in Star, Idaho. The driver of the other vehicle called law enforcement and advised them that he believed Borek was intoxicated. Officers arrived at the scene and administered breathalyzer and field sobriety tests to Borek. The breathalyzer returned a reading of .000. However, Borek was unable to perform the sobriety tests and showed other signs of impairment. Borek denied consuming alcohol but admitted that he was on anti-depressant medication. Officers arrested Borek for felony driving under the influence, in violation of Idaho Code sections 18-8004 and 18-8005(9). Officers subsequently acquired a blood sample that showed the presence of prescription medications commonly used to treat mental health conditions. Borek filed a motion to suppress all evidence obtained as a result of his arrest, arguing that officers violated the Idaho Constitution because they lacked probable cause to arrest him for a felony DUI. The district court denied Borek’s motion and Borek subsequently entered a conditional guilty plea reserving his right to appeal the denial of his motion to suppress. Borek then appealed. The Idaho Court of Appeals reversed the district court in an unpublished decision. State v. Borek, No. 49021, 2022 WL 4295418 (Idaho Ct. App. Sept. 19, 2022). It agreed with Borek that his arrest violated the Idaho Constitution because officers lacked probable cause for the felony DUI charge when they arrested him. Id., 2022 WL 4295418, at *6. Consequently, the Court of Appeals determined the district court erred when it denied Borek’s motion to suppress. Id. Accordingly, the results of Borek’s blood test and his statements made to medical staff at St. Alphonsus and Ada County Paramedics were suppressed. On remand, Borek moved to dismiss the charge and argued that, without the suppressed evidence, the State lacked probable cause to charge him with driving under the influence. The district court denied Borek’s motion. The State then filed motions for an order of delivery pursuant to Idaho Criminal Rule 17, seeking to obtain copies of Borek’s medical and prescription records from Star Pharmacy and St. Alphonsus Health System. Over Borek’s objection, the district court granted the State’s motions. The State also obtained, via subpoena, copies of records from the

2 Idaho Prescription Monitoring Program (“PMP”), Ada County Paramedics, and the Ada County Jail concerning Borek. The State provided copies of the records to Borek’s counsel. In advance of trial, Borek filed a motion in limine (the subject of this appeal) to prohibit the State from “using Borek’s private medical information.” Borek asserted several grounds, only one of which is at issue in this appeal: that the records constituted privileged communications under Idaho Rule of Evidence 503. The records at issue in Borek’s motion contained a variety of information concerning his medical conditions and prescription medications: • The PMP record is a list that indicates the dates on which Borek obtained a particular prescription medication. For each date, the list also includes the prescribing medical provider, the prescribed dose, the pharmacy where Borek obtained the medication, and other identifying information for Borek. • The Star Pharmacy records similarly concern one medication and include the prescription labels for the medication as well as an informational pamphlet explaining the conditions it treats and adverse side effects. • The Ada County Paramedics records identified Borek’s name and date of birth and indicated that paramedics drew Borek’s blood on January 17, 2020. • The Saint Alphonsus records described Borek’s medical history, including his mental health diagnosis and medication lists, medical staff’s observations of Borek on the date of the accident (i.e., his mental and physical conditions), and statements he made regarding prescription medications he had taken. • The Ada County Jail records included: (1) “Questionnaire Reports,” containing questions and answers related to Borek’s medical and mental health conditions and prescriptions; (2) “Health Services Request” forms that Borek submitted to jail staff concerning his health conditions and medications; (3) a medication administration record that identified all prescription medications that Ada County Jail medical staff administered to Borek; (4) refusal forms that Borek signed when he refused certain medications; and (5) a “Full Patient History” report that detailed a variety of information related to the medical care and assessments that jail staff provided to Borek, including medications that jail medical providers prescribed for him. In opposition, the State filed a motion asking the district court to dismiss Borek’s motion as untimely. The district court denied the State’s motion to dismiss and held a hearing on Borek’s

3 motion in limine. Borek introduced testimony at the hearing from individuals associated with or employed by the Idaho Board of Pharmacy, the Ada County Jail, and Ada County Paramedics. The testimony that Borek elicited primarily concerned whether each entity considered its records to be confidential under the federal Health Insurance Portability and Accountability Act of 1996, Pub. L. 104-191, 110 Stat. 1936 (codified as amended in scattered sections of 26, 29, and 42 U.S.C.) (“HIPAA”). During the hearing, the district court questioned counsel for the State and Borek about the applicability of Rule 503 and whether the records were “communications” within the meaning of that rule. At the conclusion of the hearing, the district court requested supplemental briefing from the parties on whether the prescription records were statements/communications.

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State v. Borek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-borek-idaho-2026.