State v. John Doe

── State v. John Doe ── Court: Idaho Court of Appeals Date: April 29, 2026 Category: General IN THE COURT OF APPEALS OF THE STATE OF IDAHO Docket No. 52047 In the Interest of: John Doe (2024-37) ) Juvenile Under Eighteen (18) Years of Age. ) STATE OF IDAHO, ) ) Opinion Filed: April 29, 2026 Petitioner-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) JOHN DOE (2024-37), ) ) Juvenile-Appellant. ) ) Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada County. Hon. Gerald F. Schroeder, District Judge. Hon. Theresa L. Gardunia, Magistrate. Opinion of the district court, on intermediate appeal, affirming the magistrate court’s decision and order, affirmed. Erik R. Lehtinen, State Appellate Public Defender; Andrea W. Reynolds, Deputy Appellate Public Defender, Boise, for appellant. Hon. Raúl R. Labrador, Attorney General; Kacey L. Jones, Deputy Attorney General, Boise, for respondent. ________________________________________________ HUSKEY, Judge John Doe appeals from the district court’s opinion, on intermediate appeal, affirming the magistrate court’s decision and order finding Doe fell within the purview of the Juvenile Corrections Act (JCA) and that he committed the offense of indecent exposure, in violation of Idaho Code § 18-4116.1 Doe argues the magistrate court erred in finding Doe committed the offense of indecent exposure because there was no evidence that another person observed his exposed genitals, which is required under the plain language of the statute. Alternatively, Doe argues there was insufficient evidence that his genitals were exposed. The State argues the plain 1 Idaho Code § 18-4116 was amended in 2025. The 2025 amendments are not relevant to this appeal. 1 language of the statute does not require another person to observe the exposed genitals and there was sufficient evidence to establish Doe exposed his genitals. We hold the plain language of I.C. § 18-4116 does not require another person to observe the exposed genitals. Additionally, there was sufficient evidence supporting the magistrate court’s findings that Doe exposed his genitals in a public place where another person was present and that person was offended, and Doe’s conduct fell within the purview of the JCA. The district court’s opinion, on intermediate appeal, affirming the magistrate court is affirmed. I. FACTUAL AND PROCEDURAL BACKGROUND In June 2023, a woman was watching a movie with her family in their home. The woman looked out her window and saw somebody riding a bicycle down the public street in front of her house. The bicyclist, later identified as Doe, was wearing a red shirt and black shorts. The woman observed that Doe’s shorts were pulled down to his knees, exposing his thigh, and the woman saw skin between the bottom of Doe’s shirt and the top of his shorts. The woman also observed Doe making an “up-and-down motion” with his hand near his leg area, which indicated to the woman that Doe was masturbating while riding his bicycle. The woman then told her fiancé. The fiancé went outside and followed Doe. The fiancé observed Doe pull up his shorts while continuing to ride his bicycle and then hide behind a bush in the yard of a nearby house. The fiancé approached Doe and asked him what he was doing. Doe responded, “nothing.” The fiancé pressed Doe further by telling Doe what the woman saw. Doe then respon