State v. Jane Doe (2024-29)

── State v. Jane Doe (2024-29) ── Court: Idaho Supreme Court Date: April 22, 2026 Category: General IN THE SUPREME COURT OF THE STATE OF IDAHO Docket No. 51814-2024 In the Interest of: ) JANE DOE (2024-29), ) Juvenile Under Eighteen (18) Years. ) Boise, January 2026 Term ----------------------------------------------- ) STATE OF IDAHO, ) Opinion filed: April 22, 2026 ) Plaintiff-Respondent, ) Melanie Gagnepain, Clerk ) v. ) ) JANE DOE (2024-29), ) ) Juvenile-Appellant. ) ) Appeal from the District Court of the Fourth Judicial District of the State of Idaho, Ada County. Gerald F. Schroeder, Senior District Judge. Theresa L. Gardunia, Magistrate Judge. The decision of the district court is affirmed. Erik R. Lehtinen, State Appellate Public Defender, Boise, for Appellant. Andrea W. Reynolds argued. Raúl R. Labrador, Idaho Attorney General, Boise, for Respondent. Mark W. Olson argued. ZAHN, Justice. Jane Doe appeals from her order of disposition for vehicular manslaughter. When Doe was sixteen years old, she killed a motorcyclist while making an illegal U-turn. The magistrate court found Doe guilty of vehicular manslaughter and imposed a sentence of ninety days in detention, with forty-eight days suspended. For the remainder of the sentence, the magistrate court ordered Doe to serve 10 days in detention and complete 250 hours of community service. Additionally, the magistrate court suspended Doe’s driver’s license for three years, imposed three years of probation, and imposed fees and court costs.  Doe appealed the sentence to the district court. Relevant to this appeal, Doe argued that the magistrate court abused its discretion because the sentence was unreasonable and failed to promote the Juvenile Corrections Act’s (“JCA”) sentencing goals of accountability, community protection, and competency development. The district court affirmed the sentence after determining that the sentence promoted the goal of accountability. Doe appeals the district court’s decision. She argues that the district court erroneously reviewed Doe’s sentence for compliance with adult (rather than juvenile) sentencing standards and that the magistrate court’s sentence failed to promote the JCA’s sentencing goals. For the reasons discussed below, we affirm the district court’s decision. I. FACTUAL AND PROCEDURAL BACKGROUND When Doe was sixteen years old, she made an illegal U-turn and collided with an oncoming motorcycle. The driver of the motorcycle died from injuries he sustained in the accident. The State filed a petition against Doe, alleging that she committed the crime of vehicular manslaughter and therefore was subject to the provisions of the JCA. Following an evidentiary hearing, the magistrate court found Doe guilty of vehicular manslaughter under Idaho Code section 18- 4006(3)(c) and concluded that Doe fell within the purview of the JCA. The magistrate scheduled a sentencing hearing and ordered that a social history report be prepared concerning Doe’s “home environment, past history, competency development, prevention or out-of-home placement services provided, and the social, physical and mental condition of the juvenile offender.” See I.C. § 20-520(1). Prior to the sentencing hearing, a juvenile probation officer filed the social history report with the magistrate court. The probation officer opined