## Facts

- Barryngton Eugene Searcy, age 20 and dependent on alcohol and cocaine, planned to obtain money for cocaine by burglarizing or robbing a grocery store in Ashton, Idaho.
- He hid in the store’s back room and watched the owner-operator, Teresa Rice, move money toward the store safe.
- When Rice discovered him, a struggle occurred and Searcy shot her in the stomach.
- Searcy induced Rice to open the safe by telling her he would call an ambulance if she did; he took the money and placed it in a backpack.
- Instead of seeking help, Searcy shot Rice in the head at close range, killing her.
- He hid the rifle and money at a nearby outdoor location; items were later found, leading to his arrest.
- Searcy later admitted the killing to a counselor during treatment, and the confession was used as evidence.
- A jury convicted Searcy of first-degree murder, robbery, and use of a firearm in the commission of a felony; the district court imposed a fixed life term without parole for murder, a consecutive indeterminate life term for robbery (with a 10-year minimum), and firearm-related enhancement time.

## Issues

1. Whether due process under the U.S. and Idaho Constitutions requires a separate insanity defense, rendering Idaho Code § 18-207 unconstitutional.
2. Whether the sentencing was legally valid, including (a) multiple firearm enhancements and (b) the fixed life-without-parole sentence and consecutive terms.
3. Whether the sentencing court erred by refusing to strike a victim impact statement in a noncapital case.

## Decision

- The Idaho Supreme Court held that due process does not require a separate insanity defense; Idaho Code § 18-207 is constitutional.
- The court held the original sentence was unlawful to the extent it imposed multiple firearm enhancements contrary to Idaho Code § 19-2520E, and it further held the trial court could not modify the sentence in the defendant’s absence.
- The court upheld the substantive sentencing determination (fixed life without parole and consecutive terms), finding no abuse of discretion given the planned nature of the robbery-murder and the execution-style killing.
- The court affirmed the refusal to strike the victim impact statement, concluding capital-case limits on victim impact evidence were inapplicable where the defendant was not sentenced to death.

## Legal Principles

- A state may abolish an insanity defense without violating due process, so long as defendants may present admissible mental-condition evidence relevant to mens rea or other required mental states.
- Idaho Code § 18-207 bars “mental condition” as an affirmative defense but permits expert evidence bearing on mens rea, subject to evidentiary rules.
- Idaho’s firearm enhancement statute does not authorize multiple separate enhancements in the manner imposed here; an illegal sentence cannot be corrected in the defendant’s absence.
- Victim impact evidence limits associated with capital sentencing do not control noncapital sentencing; a court may consider victim impact information when imposing a fixed life sentence.

## Conclusion

The court upheld Idaho’s legislative choice to eliminate an independent insanity defense while preserving mental-state evidence on mens rea, required correction of an unlawful enhancement and improper modification procedure, and affirmed the fixed-life and consecutive sentencing as well as consideration of victim impact evidence in this noncapital case.


State v. Searcy, 118 Idaho 632, 798 P.2d 914 (Idaho 1990)