Court: Idaho Supreme Court; April 19, 1993; Idaho; State Supreme Court
Quincy R. Matteson pleaded guilty to second-degree murder for the strangling death of his landlady, Barbara Overman, and was sentenced to an indeterminate life term with the first twelve years fixed. On appeal, Matteson contended that the trial court improperly considered certain evidence during sentencing, imposed a sentence that constituted cruel and unusual punishment, and abused its discretion by not waiting for a psychiatric evaluation report before ruling on a Rule 35 motion for sentence reduction.
The murder occurred on February 14, 1990, when Matteson called the police, claiming to have heard a scream and seen a man flee the scene. Upon police arrival, Overman's body was found in her bedroom with evidence of ligature strangulation. Matteson later confessed, stating that he entered her home using a key from a 'hide-a-key' box and claimed he acted after Overman screamed upon bumping into her bed. His motive for entering her home was unclear, though it was noted he had ingested cocaine prior to the murder.
Prior to the murder, Matteson had minimal criminal history, with only two traffic citations and an investigation into potential cocaine trafficking. The trial court considered letters from Overman's family detailing the impact of her murder and a psychological evaluation by Dr. Jack Stoner, which was conducted to assess Matteson's competency during the proceedings. Ultimately, Matteson was sentenced on December 7, 1990. His subsequent I.C.R. 35 motion for sentence reduction cited the lack of a psychiatric evaluation at sentencing and indicated that a new evaluation by Dr. Michael Estes was scheduled. Matteson argued this evaluation could demonstrate his reduced risk for reoffending.
Matteson sought to postpone a trial court ruling on his I.C.R. 35 motion to allow for a psychiatric report from Dr. Estes. Initially, the trial court agreed to delay, but ultimately denied the motion on September 27, 1991, approximately eight months after its filing, without receiving the report. On appeal, Matteson argued that the court improperly considered prejudicial hearsay in the presentence investigation report, victim impact statements that exceeded appropriate limits, imposed a disproportionate sentence constituting cruel and unusual punishment, and abused its discretion by not delaying the ruling until after receiving the psychiatric evaluation. He requested vacating his sentence and remanding for resentencing, but the appellate court affirmed the sentence.
Matteson claimed that a reference in the presentence report regarding an investigation into potential cocaine trafficking was prejudicial hearsay, violating State v. Mauro. However, he failed to preserve this issue for appeal, as he did not object to the report's contents during the sentencing hearing despite being given the opportunity to review it. The court stated that a defendant cannot raise challenges to a presentence report for the first time on appeal and that fundamental error principles do not apply to discretionary evidentiary rulings.
Regarding comments made by the victim's family, Matteson contended they violated his due process rights by exceeding permissible victim impact testimony. However, the court noted that victim impact statements are both allowed and mandated under Idaho law, and the relevant statutes provide for victims to express the impact of the crime during sentencing. Thus, the court found that the victim's family comments did not infringe upon Matteson's rights.
I.C. 19-5306 allows crime victims to express their opinions about the defendant and recommend a sentence at sentencing, as it does not impose any limitations on such testimony. The court has broad discretion regarding the evidence admitted during sentencing, allowing for extensive inquiry into the information considered. The trial court did not err in allowing testimony from Mrs. Overman’s family; their comments were viewed as reflections of their grief rather than influencing the sentencing decision. Matteson’s claim that this testimony prejudiced the court is unfounded, as the court did not use it to shape the punishment.
Regarding Matteson's sentence, he contends it constitutes cruel and unusual punishment due to being disproportionate to his offense. The court disagrees, referencing a modified three-step proportionality analysis under the Eighth Amendment established in prior cases. A threshold comparison of the crime and sentence must first be made to determine if there is gross disproportionality, with broader analyses only considered in rare cases. Matteson received an indeterminate life sentence with the first twelve years fixed, which the court treats as the term of confinement for appellate review purposes.
Matteson's twelve-year sentence does not suggest gross disproportionality, given the brutal nature of his crime—beating and strangling his landlady, Mrs. Overman, without any apparent motive or provocation. The act was described as senseless, aligning with the standard that a sentence must be "out of all proportion to the gravity of the offense" to be deemed cruel and unusual under the Idaho Constitution. The court found that the sentence was not excessively severe and did not shock the conscience of reasonable people.
Regarding Matteson's I.C.R. 35 motion, he claimed the trial court abused its discretion by not delaying its ruling to consider a psychiatric report. However, the court acted within its discretion, as it is required to rule on such motions within a reasonable timeframe to maintain jurisdiction. The court's eight-month delay was not unreasonable, and it was not obligated to wait indefinitely for Matteson to secure the report. Consequently, the trial court's decision to affirm the sentence was upheld.
I.C. 19-5306 mandates that victims of felony offenses must be consulted during the preparation of the presentence report, which includes their impact statements. Victims also have the right to address the court under oath at sentencing. I.C.R. 32(b)(1) requires the presentence report to detail the circumstances of the crime, incorporating the defendant’s account, the arresting officer’s report, and the victim’s perspective if relevant. The term "victim" extends to the immediate family of homicide victims as per I.C. 19-5304(1)(e). There are limitations to I.C. 19-5306 in death penalty cases, as noted in Payne v. Tennessee, but this case does not present such an issue. Additionally, Matteson supports his argument regarding sentence proportionality by comparing it to other sentences from Canyon County courts.
