Jackie Shayde Sedillo v. State of Idaho

Summary

The Idaho Supreme Court held that grand theft of an automobile is a lesser‑included offense of armed robbery under the pleading theory, so Sedillo’s double‑jeopardy claim was viable. Accordingly, the district court’s summary dismissal of Sedillo’s post‑conviction ineffective‑assistance claim was erroneous, the judgment was vacated, the summary disposition reversed, and the case remanded for further proceedings. The Court also clarified that the pleading theory, not the Blockburger test, governs double‑jeopardy analysis under the Idaho Constitution.