Verdict stands in Sagle murder case

SANDPOINT — A 1st District judge is declining to disturb the guilty verdict handed down in the second-degree murder of Elvin “Eli” Holt.

A Bonner County jury convicted James Matthew Anderson of intentionally shooting Holt to death outside Anderson’s trailer on Nov. 27, 2008. The defense argued the weapon discharged accidentally.

But the jury of seven men and five women concluded otherwise on Oct. 20.

Chief Public Defender Isabella Robertson subsequently moved to set aside the verdict and grant a judgment of acquittal or grant Anderson a new trial.

Robertson contends jurors did not consider all of the evidence presented to them and did not give

proper consideration to the jury instructions.

Robertson’s motion indicated that the jury based its verdict on beliefs that Anderson was in the wrong for retrieving the .44-caliber revolver used in the shooting and that a warning shot should have been fired into the air before Holt was killed.

Neither of those beliefs are material elements of the charge Anderson was convicted of.

Robertson argued that the jury’s considerations ran afoul of Anderson’s right to receive a fair trial by an impartial jury.

“The information that I have clearly indicates that at least one juror declined to follow the jury instructions, basing their verdict on other issues,” Robertson said during a hearing on Tuesday.

Robertson declined to identify the female juror who confided in her or further elaborate on the woman’s remarks.

Jury verdicts in Idaho criminal matters must be unanimous and the deliberations which precede them are sacrosanct. Idaho rules of evidence forbid jurors from being called to testify about their deliberations unless there are questions whether extraneous prejudicial information was put before them or if they resorted to chance in reaching a verdict.

Robertson maintained the length of deliberations — about 3 1/2 hours — was suspect. Prosecutor Louis Marshall countered that the defense could point to no case law which dictates how long deliberations should take.

Marshall argued the defense’s position had no traction in light of the rules of evidence concerning inquiries into the validity of a jury’s verdict.

“I don’t think there is a means or an avenue — legally — for the court do go down that road,” he said.

Verby agreed and noted during the hearing that Anderson indicated to  dispatchers on the night of Holt’s death that the shooting was not accidental and there was no reason for the killing.

Verby also cited a recent Idaho Court of Appeals case governing the sufficiency review of evidence supporting a jury’s verdict.

“In this case, I must consider the verdict in light most favorable to the prosecution and upon that basis I do find that there is substantial evidence upon which a reasonable trier of fact could have found that the prosecution sustained its burden of proving the essential elements of the crime beyond a reasonable doubt,” he said.