Paul Rhoades, Petitioner-Appellant v. State of Idaho, and Tom Beauclair

Summary

The Idaho Supreme Court affirmed summary dismissal of Paul Ezra Rhoades' 2005 petition for post-conviction relief as time-barred under I.C. § 19-4902. Reaffirming Charboneau, the Court held equitable tolling is available only for claims raising "important due process issues" that are adequately supported by admissible facts: Rhoades' prosecutorial misconduct claim rested on an unreasonable chain of four inferences, his actual-innocence claim failed the Schlup standard because the PGM evidence pertained to the Michelbacher case rather than the Haddon charges to which he pleaded, his ineffective-assistance claim was knowable at trial's end, and his DNA-testing request fell outside I.C. § 19-4902(b) and implicated no due process right. The Court expressly reserved whether due process requires a free-standing actual-innocence exception, denied attorney fees under I.C. § 12-121 because the appeal was not frivolous, and awarded costs to the state under Idaho Appellate Rule 40.