What will be decided on February 9, 2023?
What Will the Court Rule
This Week?
February 6, 2023
Hello Good Friends!
First, thanks to all of you who watch my True Crime Wednesday and Friday night TGIF YouTube offerings. I love spending time with all of you. If you haven’t checked out the show yet, you can find it here: https://www.youtube.com/channel/UC6DDIwubCEwP2U0hIS6NLKg.
There are lots of things to talk about in this newsletter, so buckle up because it’s going to be long. First, I’ll outline the recent legal developments in the Vallow/Daybell case, then answer some questions that have come up in the Murdaugh case. The newsletter is where I go in-depth, but I’ve tried to categorize things so you can skip the things you aren’t interested in.
Lori Vallow/Chad Daybell. A hearing is scheduled for January 9, 2023, at 9 am in Rexburg. I won’t be attending, because I will be visiting my daughter to help with plans for her wedding.
Here are the issues the judge will be decided at that hearing.
Motion to Dismiss for Lack of Speedy Trial. This is Lori’s motion to dismiss her case because her speedy trial rights have been violated. Interestingly, Lori’s team outlines the entire period of her incarceration since her arrest in Hawaii on February 20, 2020. They point out that she has been incarcerated for 1169 days but concede that the time, in this case, runs from when she was arraigned on April 19, 2022. The first trial setting on October 11, 2022, was within her six-month speedy trial window. However, the state asked for a three-month continuance. They argued that they needed to resolve issues surrounding the consumptive DNA testing, and Lori’s new attorneys needed time to get up to speed.
The state cited several cases on the subject, “Idaho courts have determined that judicial review was warranted in several instances: in a delay of nine months between complaint and arrest (State v. Holtslander, 102 Idaho 306 (1981)); forty-two days after the expiration of the six-month statutory time period (State v. Beck, 128 Idaho 416 (Ct. App 1996)); and a one-month delay for trial (State v. Wengren, 126 Idaho 662 (Ct. App. 1995)). See also State v. McNew, 131 Idaho 268, 271-272 (Ct. App. 1998) for summary. However, the U.S. Supreme Court has held that for constitutional purposes, a “delay is not presumptively prejudicial until it approaches one year.” Doggett v. United States, 505 U.S 647, 652 n.1 (1992).”
Judge Boyce agreed that there was good cause for that first delay and continued the case until January 9, 2023. In late September, Lori’s team once again raised the issue of whether she was competent to aid and assist her in her defense, and on October 6, 2022, Judge Boyce once again continued the case. At the time the judge vacated the January 9, 2023, trial date, Lori’s status was unknown, and the judge, out of an abundance of caution, took the January trial date off, in part because of the tremendous amount of planning that will be required to hold the trial in Ada County. On November 15, 2022, the judge ruled that Lori was competent to stand trial.
The question of whether the delay is legal turns on the definition of “good cause.” The controlling Idaho case on the subject is State v. Clark, 135 Idaho 255 (2000). In that case, the court said, “We therefore conclude that good cause means that there is a substantial reason that rises to the level of a legal excuse for the delay. Because there is not a fixed rule for determining good cause for the delay of a trial, the matter is initially left to the discretion of the trial court.” Lori’s defense team contends that there was not good cause for the delay in bringing Lori to trial.
The state argues that at least some of the delay must be attributed to Lori and that any delay was for good cause. Let’s remember that in Idaho if the defendant asks for a delay in trial for any reason, even if the later trial setting is within the six-month window, it is considered a waiver of speedy trial. In this case, Lori never asked for a continuance and never waived her right to a speedy trial. However, except for the October 11, 2022, to January 9, 2023 delay, all of the delay was because of issues with her competency. According to the computations of Lori’s attorneys, the resulting delay is about 40 days.
I believe the judge will deny this motion. It’s an issue rarely, if ever, decided at the trial level but will undoubtedly be pivotal on appeal.
That brings me to the rumors of plea agreements. We have heard in court that plea agreements were offered. Lori’s counsel asked that she be able to meet with Chad to discuss the plea offer, and that motion was denied. Rumors were swirling among people I talked to that plea negotiations were going on. I suspect those discussions were unsuccessful because we have seen a redoubling of trial preparation.
Motion for Individual Voir Dire. Typically, jurors are questioned in canvass-style question sessions, where the attorney will ask the entire panel questions and ask people to raise their hand if the question applies to them. For example, an attorney might ask, “how many of you have children?” If a juror raises their hand, the attorney will follow up with questions about how many children and their ages. That kind of questioning is more efficient than individual juror interviews. Lori’s attorneys are asking to interview each juror separately about the most sensitive subjects to protect their case and any personal information a juror might share. What is interesting about that motion is that the defense specifically cites the topics of punishment (whether they could impose the death penalty), mental health issues, domestic violence, or drug use. They contend that the collective style of questioning “as to their familiarity with the crime, the victims, or the prior legal proceedings in this case, will educate all jurors to prejudicial and incompetent material…” The state agrees that the case “necessitates a voir dire process which allows the Court and all parties to ascertain individual jurors’ opinions on certain sensitive topics.” They then ask that the questioning be done in small panels rather than individually. For those watching the Murdaugh case, the jury questioning in the Murdaugh case was done in small panels. That format allows for more individualized questioning while still being efficient. I believe the judge will approve some sort of hybrid, where the initial questions are posed in small panels, and then jurors are pulled in for individual in-depth questions, depending on their answers.
Motion to Disclose Penalty Phase Information. Lori’s defense team filed this motion. They ask that the Court order “that the State disclose any information in its possession and/or the possession of any law enforcement agencies which might be potentially relevant or admissible at the penalty phase of this case, should that phase of this case ever be reached.” This is a typical procedural motion. The defense demands that the state turn over any information they intend to offer during the sentencing phase of the trial. The state is required to do so, and Lori’s team is making sure that their request is documented ahead of the penalty phase. The information they are asking for includes information that supports or refutes any statutory aggravating factors, any expressions of remorse by the defendant, cooperation with law enforcement, any information about the defendant’s satisfactory adjustment to incarceration, and any victim impact statements.
Motion for Preselection Instructions to Potential Jurors. Throughout the trial process, jurors are given instructions. To ensure those instructions are consistent, they are generally decided before the trial begins. Like most states, Idaho has a set of written uniform jury instructions. However, the court can deviate from those uniform instructions, and lawyers often ask the court to change the wording or tweak the instructions. Jury instructions are given at different times and in different phases of the trial. The defense is asking for the following jury instruction:
“Members of the jury, the process we are about to begin is known as voir dire. The attorneys for the State and the Defendant will have the opportunity to ask you questions regarding your qualifications to serve on this jury. It is important that you be as honest as you can be in your responses to questions put to you by counsel.
LORI VALLOW DAYBELL is charged with First Degree Murder and Conspiracy to Commit First Degree Murder and Grand Theft. The penalty for both First-Degree Murder, and Conspiracy to Commit First Degree Murder and Grand Theft is either death or life in prison without the possibility of parole. Since one of the possible penalties for the offense of First Degree Murder and/ or Conspiracy to Commit First Degree Murder and Grand Theft is the Death Penalty, it is necessary that counsel ask you certain questions about your views regarding the death penalty.
In this regard, I give you the following instructions: The law provides that the jury first hears the case and determines whether the defendant is guilty or not guilty. If the jury finds the defendant not guilty or guilty of an offense other than First-Degree Murder or Conspiracy to Commit First Degree Murder and Grand Theft, your jury service is complete. If the defendant is found guilty of First-Degree Murder and / or Conspiracy to Commit First Degree Murder and Grand Theft then the jury must consider the issue of punishment. If the Defendant is found guilty of First-Degree Murder and /or Conspiracy to Commit First Degree Murder and Grand Theft, then the State and the Defendant have the opportunity to present evidence with regard to punishment. The jury then will hear argument from the State and the Defendant for or against a sentence of death. The Court then will give the jury instructions as to the law that applies regarding punishment.
Each juror will be required to decide:
(1) Whether the State has proved beyond a reasonable doubt the existence of any aggravating circumstances - the Court will define what constitutes an aggravating circumstance;
(2) Whether the State has proved beyond a reasonable doubt that the aggravating circumstance or circumstances found is, or are, sufficient to outweigh any mitigating circumstance or circumstances that you might find; and (4) Whether the State has proved beyond a reasonable doubt that any aggravating circumstance or circumstances that you find is, or are, when considered together with the mitigating circumstances found, sufficiently substantial to call for the imposition of the death penalty.
To repeat, the jury only considers punishment if it first finds the Defendant guilty of First Degree Murder and /or Consporacy [sic] to Commit First Degree Murder and Grand Theft.
If you are selected as a juror you will take an oath that you will try all matters that come before you and render true verdicts according to the evidence. If the Defendant is found guilty of First Degree Murder and or Conspiracy to commit First Degree Murder and Grand Theft, then the jurors’ duty would be to follow conscientiously the instructions of the Court regarding the sentence and to consider fairly both of the penalties provided by law -- the death penalty and life imprisonment without parole regardless of your personal views concerning capital punishment. It is acceptable for jurors to have different opinions about the death penalty and to have different views about what circumstances call for the death penalty. You are never required to return a sentence of death in any case. The law does require however, that you give consideration to both penalties notwithstanding your personal views regarding capital punishment, just as it is a juror’s duty to apply the law as the Court explains it to you, not as you think it is or think it should be.
The questions counsel will be asking you or similar questions are asked in every case of First Degree Murder and/ or Conspiracy to commit First Degree Murder and Grand Theft in which one of the possible penalties is death. The law requires that such questions be asked. In responding to the questions concerning the death penalty, you must keep in mind your duty as a juror as I have just explained it to you.”
The instruction is informative and reasonably neutral. While I don’t know what the judge will rule, I’m interested in what he says about this. Of course, it’s a high-stakes case, and he may stick to the tried-and-true instructions.
Discovery Motions. Several discovery motions and motions to compel will be heard on February 9, 2023. At the last hearing, Judge Boyce denied Chad Daybell’s motion to continue the trial. Prior originally asked for a continuance because he needed more time to prepare for a possible mitigation phase by hiring a mitigation specialist. At the hearing, however, Prior focused on the fact that he had still not received the results of the consumptive DNA testing and that some new evidence had recently been discovered and needed to be tested for DNA. He argued that either of the samples could be exculpatory. The judge denied the motion to continue, citing Lori’s lack of speedy trial waiver, but indicated that if the state did not immediately produce the DNA results, the judge would consider severing the cases to allow Daybell more time to investigate the DNA results. The state obtained the DNA data three days later and provided it to the defense. John Prior filed his motion to compel the production of the DNA evidence on the same day the state filed its Discovery Disclosure of the outstanding DNA evidence. Prior still contends that he needs more time for his DNA expert to analyze the results. He also reminded the court that there was an outstanding motion to sever and noticed the parties that the hearing on that motion would also be on February 9, 2023. Expect that day to be a full day of motions.
Motion to Sever. Once again, Prior seeks to sever Chad’s trial from Lori’s. While the judge suggested that he might sever if the DNA evidence wasn’t immediately produced, the evidence was provided right away, and I don’t believe he will sever the trials.
Motion in Limine. On January 3, 2023, Lori’s team filed a Notice of Intent Not to Raise Mental Health Defense. The state then asked the judge for a pretrial order limiting any evidence on Lori’s mental health. A motion in limine asks the judge to make pretrial evidentiary determinations to ensure that the jury doesn’t hear improper information. The defense objected to the motion. The state wants the court to prohibit the defense from presenting expert witnesses to discuss Lori’s mental health. Idaho Code §18-207(1) provides: “Mental condition shall not be a defense to any charge of criminal conduct.” I.C. §18-207(3) states: “Nothing herein is intended to prevent the admission of expert evidence on the issue of any state of mind which is an element of the offense, subject to the rules of evidence.” The state contends correctly that the defense was required to give notice of their intent to offer any evidence to negate any state of mind element of the charge. Not only did they not give notice, but they specifically said they would not raise the issue. The state wants a pretrial ruling that if it offers evidence of Lori’s beliefs, it won’t “open the door” for the defense to bring up her mental illness. We are going to talk about evidence rule 403 and opening the door in the discussion of the Murdaugh case below, but in short, the state doesn’t want the defense to be able to argue that Lori’s beliefs are a delusional condition. We’ve discussed when a religious belief becomes a diagnosable religious delusion.
The defense objection states that they do not intend to call any expert witnesses about Lori’s mental health. They say that Lori’s position is that she did not commit any crime, so there is no mental state to negate. But, they say, Lori’s mental illness is well documented, so they cannot agree that she is free from it. None of their response directly addresses the state’s contention that they should not be able to open the door.
Based on the defense’s earlier notice, I believe the judge will rule that they can’t present any information about Lori’s mental health and that the state introducing her religious beliefs will not open the door for the defense to offer any mental health evidence.
Other Notices. On January 25, 2023, John Prior filed a Notice of Service. That notice reports that Prior served Daybell’s Notice of Alibi, a disclosure of his intent to call a Forensic Pathologist, and a list of witnesses on the state. This is interesting because, unlike Lori’s attorney, Prior has not filed the Notice of Alibi with the court.
Objection to IRE 404(b). Daybell’s attorney has filed something titled Objection to IRE 404(b). The objection is to “the introduction of all requested evidence by the State pursuant to IRE 404(b). The request is not timely. The court must first conduct an evidentiary hearing as it relates to such evidence.” It’s unclear from the caption and the court database which motion this may apply to. There have been several filings and a hearing that were sealed that may relate to this objection. 404(b) specifically relates to prior bad acts. We don’t know what it is that the prosecution wants to introduce. Read on for a discussion of 403 and 404 evidence.
Alex Murdaugh and South Carolina Rules of Evidence (SCRE) 403 and 404. In most states, the rules of evidence mirror the Federal Rules of Evidence, with some minor changes. While this discussion is specifically about the rules in South Carolina, the rules in Idaho are similar.
There has been much discussion about these rules during the past two weeks of the Alex Murdaugh trial, and many questions. Let’s start with the text of the rules
RULE 403
EXCLUSION OF RELEVANT EVIDENCE ON GROUNDS OF PREJUDICE, CONFUSION, OR WASTE OF TIME
Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.
Note:
This rule is identical to the federal rule and is consistent with the law in South Carolina. State v. Alexander, 303 S.C. 377, 401 S.E.2d 146 (1991) (relevant evidence may be excluded where its probative value is substantially outweighed by the danger of unfair prejudice); State v. Hess, 279 S.C. 14, 301 S.E.2d 547 (limitation of defense testimony upheld where it was merely cumulative to other testimony), cert. denied, 464 U.S. 827, 104 S.Ct. 100, 78 L.Ed.2d 105 (1983); State v. Gregory, 198 S.C. 98, 16 S.E.2d 532 (1941) (trial judge properly limited the defendant’s presentation of certain evidence to guard against confusion of the jury by the injection of collateral issues).
RULE 404
CHARACTER EVIDENCE NOT ADMISSIBLE TO PROVE CONDUCT; EXCEPTION; OTHER CRIMES
(a) Character Evidence Generally. Evidence of a person’s character or a trait of character is not admissible for the purpose of proving action in conformity therewith on a particular occasion, except:
(1) Character of Accused. Evidence of a pertinent trait of character offered by an accused, or by the prosecution to rebut the same;
(2) Character of Victim. Evidence of a pertinent trait of character of the victim of the crime offered by an accused, or by the prosecution to rebut the same, or evidence of a character trait of peacefulness of the victim offered by the prosecution in a homicide case to rebut evidence that the victim was the first aggressor;
(3) Character of Witness. Evidence of the character of a witness, as provided in Rules 607, 608, and 609.
(b) Other Crimes, Wrongs, or Acts. Evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible to show motive, identity, the existence of a common scheme or plan, the absence of mistake or accident, or intent.
Note:
Rule 404(a) is identical to the federal rule and is consistent with the law in South Carolina. State v. Peake, 302 S.C. 378, 396 S.E.2d 362 (1990).
Rule 404(a)(1) is identical to the federal rule and is consistent with the law in South Carolina. State v. Lyles, 210 S.C. 87, 41 S.E.2d 625 (1947) (a defendant may put in evidence of his good character); State v. Major, 301 S.C. 181, 391 S.E.2d 235 (1990) (when the accused offers evidence of his good character regarding specific character traits relevant to the crime charged, the state may cross-examine as to acts relating to the traits focused on by the accused).
Rule 404(a)(2) identical to the federal rule and is consistent with the law in South Carolina. State v. Boyd, 126 S.C. 300, 119 S.E. 839 (1923).
Rule 404(b) differs in two respects from the federal rule. First, unlike the federal rule which does not limit the purposes for which evidence of other crimes may be admitted, the South Carolina rule limits the use of evidence of other crimes, wrongs, or acts to those enumerated in State v. Lyle, 125 S.C. 406, 118 S.E. 803 (1923). See also Citizens Bank of Darlington v. McDonald, 202 S.C. 244, 24 S.E.2d 369 (1943) (Lyle applicable in civil cases). Second, the South Carolina rule does not contain the requirement which is in the federal rule that, upon request by an accused, the prosecution must provide reasonable notice of the general nature of any evidence it intends to introduce under the rule. With the exception of notice of evidence to be used in aggravation in the sentencing phase of capital cases, S.C. Code Ann. § 16-3-20(B) (Supp. 1993), there is no similar requirement under South Carolina law. The rule does not set forth the burden of proof required for the admission of evidence of bad acts, not the subject of a conviction and, therefore, case law would control. State v. Smith, 300 S.C. 216, 387 S.E.2d 245 (1989) (in a criminal case, evidence of other crimes or bad acts must be clear and convincing if the acts are not the subject of a conviction). Further, when the prejudicial effect of evidence substantially outweighs its probative value, the evidence may be excluded under Rule 403, which is consistent with prior case law. State v. Garner, 304 S.C. 220, 403 S.E.2d 631 (1991).
Under Rule 403, all evidence must be more probative than prejudicial. A good example is State v. Spears 403 S.C. 247, 250 (S.C. Ct. App. 2013). In that case, the defendant was accused of killing a victim who had been convicted in a gang shooting four years prior. The murder occurred just a month after the victim had been released from a prison term for that earlier shooting. The defense argued that introducing the information that the murder was likely a gang-related revenge killing was more prejudicial than probative. Upon completion of the arguments, the trial court found the gang affiliation evidence was relevant, and any danger of unfair prejudice did not substantially outweigh the probative value of the evidence it might have caused. Rules 404(b) and 403 are intertwined and complex to parse out. The defense also argued that the admission of information about the defendant’s gang affiliation was not permitted under Rule 404(b) because it was improper character evidence. The prosecutor argued that the evidence of the defendant’s gang affiliation was necessary to prove motive, intent, common scheme or plan, or identity.
The South Carolina Supreme Court ruled in State v. Spears 403 S.C. 247, 250 (S.C. Ct. App. 2013, “South Carolina law precludes evidence of a defendant’s prior crimes or other bad acts to prove the defendant’s guilt for the crime charged, except to establish: (1) motive; (2) intent; (3) the absence of mistake or accident; (4) a common scheme or plan embracing the commission of two or more crimes so related to each other that proof of one tends to establish the other; or (5) the identity of the perpetrator. Rule 404(b), SCRE. “Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” Rule 403, SCRE. “Unfair prejudice means an undue tendency to suggest [a] decision on an improper basis.” State v. Gilchrist, 329 S.C. 621, 627, 496 S.E.2d 424, 427 (Ct.App.1998). “Once bad act evidence is found admissible under Rule 404(b), the trial court must then conduct the prejudice analysis required by Rule 403, SCRE.” State v. Wallace, 384 S.C. 428, 435, 683 S.E.2d 275, 278 (2009) (emphasis added). The court may exclude the 404(b) evidence if the probative value of the evidence is substantially outweighed by the danger of unfair prejudice to the defendant. Id.
The judge in Spears allowed the gang- affiliation information to come in but failed to put his analysis of the issue on the record to prove he had conducted the necessary “balancing test.” As a result, the Supreme Court ordered the case remanded to the trial court for a new trial.
This is why Judge Newman has carefully heard all the 404 evidence in the Murdaugh case outside the jury’s presence.
Now, about “opening the door.” The idea is that if one side raises an issue or area of inquiry that the rules of evidence would otherwise prohibit, they open the door for the other side to pursue that line of investigation. The idea has some limitations because it’s based on assuring the other side isn’t prejudiced by one side’s introduction of prohibited evidence. The easiest example is the one that comes directly from the Murdaugh case. In general, Rule 404(a) prohibits the introduction of a person’s character. However, Murdaugh’s attorneys opened the door on that evidence by asking witnesses whether Murdaugh was a good father and husband and other questions about his overall demeanor. The most explosive question, the one that blew the door open, was the question as to whether the witness could think of any reason Murdaugh might kill his wife and son. It seems like a big blunder for a couple of seasoned lawyers, so it’s unclear what their reasoning was in asking that question. It allowed the state to ask whether the witnesses were aware of Murdaugh’s theft or that he was under pressure from his firm to account for a huge sum of missing money.
I expect Judge Newman to rule that Murdaugh’s lawyers opened the door with their questions about his character and to allow the evidence of Murdaugh’s prior bad acts in to prove his motive for the crime.
Motive. As anyone who follows true crime already knows, the prosecution need not ever prove motive. Why a crime was committed is never an element of the crime. But juries are human, and it’s human nature to wonder why a crime was committed. It’s certainly difficult to fathom why someone would brutally murder their wife and son, and it will be easier for the jury to convict if they understand some reason for the crime, no matter how irrational. So let’s look at the state’s theory about Murdaugh’s motive.
Alex Murdaugh had been stealing money from clients since 2010. The pace of his theft picked up over time. He stole money in several ways; he misdirected client money into his own accounts, he took attorney fees that should have been paid to his firm, and he borrowed money from client accounts with the help of his friendly banker. The entire scheme came to light when Murdaugh tried to keep a $792,000 fee that should have been turned over to his firm. The case was handled jointly with his best friend, lawyer Chris Wilson. When Wilson distributed the settlement proceeds, Murdaugh told his friend that he was attempting to structure the fees into an annuity for his wife (and thereby shelter it from being seized in a pending lawsuit against him). He told Wilson his firm knew about the deal and was aware the payout was being made directly to him. Murdaugh received the payment for his fees, but when his firm began to question where the money was, he returned most of the proceeds ($600,000) to Chris Wilson’s lawyer trust account and asked Wilson to confirm to the firm that the money was still in Wilson’s account. Lawyer trust accounts contain money that belongs to someone other than the lawyer. They are monitored by the state bar, and irregularities can result in disbarment. When Wilson realized the money he had paid Murdaugh belonged to Murdaugh’s firm, he panicked, made up the remaining $192,000 from his own funds, and then notified Murdaugh’s firm the money was in his trust account.
The morning of the murders, his firm’s Chief Financial Officer confronted Murdaugh about all the irregularities, including accusing him of misdirecting client money for his own use. In the middle of that meeting, Murdaugh took a call. The call was from a family member telling him that his father, Randolph Murdaugh (who had also been a member of the firm), was dying. The CFO, who had been with the company a long time, immediately dropped the subject of the misappropriation and became a concerned friend. That was when Murdaugh understood that if he could shift the narrative and appear as a victim, he could buy himself some time. He was trying to refinance his real property to make up for some of the shortfalls. He thought he could move things around and cover his tracks with enough time. His aging father’s impending death had gained him some time, but he couldn’t be sure when and if his father would die. In his panicky and irrational state of mind, he saw putting himself in the position of grieving spouse and father as the only alternative to buy him the extra time he needed. While most people would see this as an absurd reaction, it made sense to Alex Murdaugh in the moment. Maggie’s estate was worth about $5 million. He had moved the real property into her name to protect it from seizure, but she was being difficult about refinancing the properties. It’s possible his son, Paul, was simply collateral damage. Still, Paul was also the primary defendant in a multimillion-dollar wrongful death case, and his death would make that case more difficult for the plaintiffs to pursue.
Alex Murdaugh’s decision to murder his wife and son was the action of a panicky narcissist in search of a quick solution to an impending disaster of his own making.
It will be up to the jury to decide how much, if any, weight to give the state’s theory.
A few other items of note, Kay and Larry Woodcock have encouraged the community to write to Judge Boyce to encourage him to reconsider this ban on cameras in the courtroom at trial. If you are interested in writing a letter at Kay and Larry’s request, you can address it to:
The Honorable Steven W. Boyce
c/o Clerk of the Court
Regarding Case Numbers CR22-21-1623 and CR22-21-1624
Fremont County Court
151 W. 1st N.
Saint Anthony, ID 83445
