State v. Muguira

CourtIdaho Court of Appeals
DecidedDecember 23, 2025
Docket52144
StatusUnpublished

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

Bluebook
State v. Muguira, (Idaho Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 52144

STATE OF IDAHO, ) ) Filed: December 23, 2025 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED JOHN MICHAEL MUGUIRA, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) )

Appeal from the District Court of the Third Judicial District, State of Idaho, Canyon County. Hon. Davis F. VanderVelde, District Judge.

Judgment of conviction and sentence of twenty-seven and one-half years with ten years determinate for felony driving under the influence, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Sally J. Cooley, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Neil Paterson, Deputy Attorney General, Boise, for respondent. ________________________________________________

GRATTON, Chief Judge John Michael Muguira appeals from the judgment of conviction and sentence of twenty- seven and one-half years with ten years determinate for felony driving under the influence. Muguira argues the district court erred in failing to instruct the jury on the defense of necessity. Muguira also contends the district court abused its discretion by imposing an excessive sentence and denying his Idaho Criminal Rule 35 motion. I. FACTUAL AND PROCEDURAL BACKGROUND Muguira was involved in an altercation in the parking lot of a bar. Upon arrival, officers encountered multiple people in an intersection outside the bar. A yellow motorcycle was laying in the middle of the road and Muguira was attempting to stand it up. An officer noticed the strong odor of alcohol emanating from Muguira, his slurred speech, and unsteadiness on his feet. Muguira

1 also had road rash, consistent with a motorcycle accident. Muguira acknowledged to officers that he tried to drive out of the parking lot and crashed the motorcycle in the intersection. Muguira failed field sobriety tests and registered a breath alcohol level of 0.158, refusing a second breath test. After booking into the jail, Muguira made several recorded phone calls in which he acknowledged that he tried to leave the area on the motorcycle and wrecked. The State charged Muguira with the crimes of felony driving under the influence (DUI), Idaho Code §§ 18-8004, 18-8005; two counts of misdemeanor battery, I.C. § 18-903; and misdemeanor malicious injury to property, I.C. § 18-7001(1). Muguira was also alleged to be a persistent violator, I.C. § 19-2514. During trial, Muguira requested an instruction on the defense of necessity. Muguira argued the necessity instruction was warranted because there was evidence there was a fight, he was fleeing his attackers, and he could take no other action than drive away on the motorcycle. The State argued there was no reasonable view of the evidence that would support a necessity instruction. The district court found the evidence was insufficient to warrant giving the necessity instruction. After trial, the jury acquitted Muguira on the battery and malicious injury to property charges but could not reach a verdict on the DUI charge. Upon retrial, the jury convicted Muguira of felony DUI. Muguira admitted to the felony enhancement and being a persistent violator. The district court sentenced Muguira to a unified term of twenty-seven and one-half years with ten years determinate. Muguira filed an I.C.R. 35 motion, which the district court denied. Muguira appeals. II. STANDARD OF REVIEW Whether a jury has been properly instructed is a question of law over which we exercise free review. State v. Severson, 147 Idaho 694, 710, 215 P.3d 414, 430 (2009). When reviewing jury instructions, we ask whether the instructions as a whole, and not individually, fairly and accurately reflect applicable law. State v. Bowman, 124 Idaho 936, 942, 866 P.2d 193, 199 (Ct. App. 1993).

2 III. ANALYSIS Muguira argues the district court erred in failing to instruct the jury on the defense of necessity. Muguira also contends the district court abused its discretion by imposing an excessive sentence and denying his I.C.R. 35 motion. A. Necessity Instruction Muguira claims his right to present a complete defense under the Sixth Amendment to the United States Constitution was violated when the district court failed to give a necessity instruction to the jury. A trial court presiding over a criminal case must instruct the jury on all matters of law necessary for the jury’s information. I.C. § 19-2132; Severson, 147 Idaho at 710, 215 P.3d at 430. In other words, a trial court must deliver instructions on the rules of law that are material to the determination of the defendant’s guilt or innocence. State v. Mack, 132 Idaho 480, 483, 974 P.2d 1109, 1112 (Ct. App. 1999). Each party is entitled to request specific instructions. State v. Weeks, 160 Idaho 195, 198, 370 P.3d 398, 401 (Ct. App. 2016). However, such instructions will only be given if they are “correct and pertinent.” I.C. § 19-2132. A proposed instruction is not “correct and pertinent” if it is: (1) an erroneous statement of the law; (2) adequately covered by the other instructions; or (3) not supported by the facts of the case. Severson, 147 Idaho at 710-11, 215 P.3d at 430-31; State v. Weeks, 160 Idaho 195, 198, 370 P.3d 398, 401 (Ct. App. 2016). There is no entitlement to a jury instruction on a legal theory of defense when no reasonable view of the evidence supports the elements of the instruction. State v. Howley, 128 Idaho 874, 878, 920 P.2d 391, 395 (1996). If the requested instruction is not supported by the evidence, the trial court must reject the requested instruction. Id. The question of whether there is a reasonable view of the evidence that supports an instruction to the jury on the necessity defense is a matter of discretion for the district court. Id. When a trial court’s discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine whether the trial court: (1) correctly perceived the issue as one of discretion; (2) acted within the boundaries of such discretion; (3) acted consistently with any legal standards applicable to the specific choices before it; and (4) reached its decision by an exercise of reason. State v. Herrera, 164 Idaho 261, 270, 429 P.3d 149, 158 (2018).

3 The defense of necessity is based on the premise that a person who is “compelled to commit an illegal act in order to prevent a greater harm should not be punished for that act.” State v. Hastings, 118 Idaho 854, 855, 801 P.2d 563, 564 (1990). “The elements of the defense are: (1) a specific threat of immediate harm; (2) the circumstances which necessitate the illegal act must not have been brought about by the defendant; (3) the same objective could not have been accomplished by a less offensive alternative available to the actor; and (4) the harm caused was not disproportionate to the harm avoided.” State v. Young, 157 Idaho 280, 285, 335 P.3d 620, 625 (Ct. App. 2014).

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Related

State v. Severson
215 P.3d 414 (Idaho Supreme Court, 2009)
State v. Huffman
159 P.3d 838 (Idaho Supreme Court, 2007)
State v. Hernandez
822 P.2d 1011 (Idaho Court of Appeals, 1991)
State v. MacK
974 P.2d 1109 (Idaho Court of Appeals, 1999)
State v. Howley
920 P.2d 391 (Idaho Supreme Court, 1996)
State v. Lopez
680 P.2d 869 (Idaho Court of Appeals, 1984)
State v. Chisholm
882 P.2d 974 (Idaho Court of Appeals, 1994)
State v. Allbee
771 P.2d 66 (Idaho Court of Appeals, 1989)
State v. Toohill
650 P.2d 707 (Idaho Court of Appeals, 1982)
State v. Hastings
801 P.2d 563 (Idaho Supreme Court, 1990)
State v. Forde
740 P.2d 63 (Idaho Court of Appeals, 1987)
State v. Knighton
144 P.3d 23 (Idaho Supreme Court, 2006)
State v. Oliver
170 P.3d 387 (Idaho Supreme Court, 2007)
State v. Bowman
866 P.2d 193 (Idaho Court of Appeals, 1993)
State v. Troy Cameron Young
335 P.3d 620 (Idaho Court of Appeals, 2014)
State v. Jesse Jay Weeks
370 P.3d 398 (Idaho Court of Appeals, 2016)
State v. Herrera
429 P.3d 149 (Idaho Supreme Court, 2018)
State v. Biggs
480 P.3d 150 (Idaho Court of Appeals, 2020)

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State v. Muguira, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-muguira-idahoctapp-2025.