Paul Ezra Rhoades has lost his first appeal to the Idaho Supreme Court in the murder of an eastern Idaho man nearly four years ago.
Still pending are other appeals in two first-degree murders and subsequent death sentences.The court on Friday unanimously upheld the life sentence ordered for Rhoades after he pleaded guilty to second-degree murder in the March, 1987, slaying of convenience store clerk Nolan Haddon.
In a key portion of the ruling, the Supreme Court said when Rhoades blurted out, "I did it," when first approached by investigators, that was a voluntary, spontaneous statement and officers did not have to precede it with a warning about his legal rights.
Rhoades, who was convicted and sentenced to die for two other eastern Idaho robbery-slayings about the same time, pleaded guilty to shooting Haddon but preserved the right to test key issues on appeal.
Rhoades was sentenced to die for killing Idaho Falls teacher Susan Michelbacher and Blackfoot convenience store clerk Stacy Baldwin.
The Haddon case was heard by Larry Boyle of Idaho Falls, then a district judge but now a member of the Supreme Court. Boyle disqualified himself from hearing the appeal and did not take part in Friday's ruling.
Justice Stephen Bistline also did not take part in the case. District judges Gerald Schroeder of Boise and George Reinhardt of Grangeville participated in the case and joined in the decision written by Justice Charles McDevitt.
The court ruled:
- That Boyle properly refused to make a pre-trial ruling on the legality of Idaho's 1982 abolition of the insanity defense in criminal cases.
- The "I did it" confession and other statements by Rhoades were properly admitted at the trial.
- It is not necessary for alleged confessions to be tape-recorded, as is required in Alaska.
- Boyle correctly allowed testimony by two jailhouse informants that Rhoades confessed the Haddon slaying to them, with a warning to the jury that such testimony was highly unreliable.
- It was not necessary for Boyle to disqualify himself from the Haddon case after earlier sentencing Rhoades to die in the Michelbacher murder case because the judge did not order the death penalty in the second case.
- It also was not necessary for the prosecution to turn over certain police reports about Kevin Buckholz, who claimed to have killed Baldwin.
"The defense had the information that there was a confession to the Baldwin murder, the identity of the confessor, the details of the confession and the name of the officer who heard the confession," the court said. With that, the defense could have contacted the officers involved to determine whether the confession was worth pursuing.
Three years ago, Salt Lake police named Rhoades as their prime suspect in the killings of three Utah women, who were shot with the same .38-caliber handgun. Rhoades denied any part in the killings, which occurred in 1985 and 1986, and no charges have been filed.