State v. Augerlavoie

Summary

The Idaho Supreme Court affirmed Augerlavoie’s convictions and persistent-violator enhancement. It held that the trial judge’s direction to correct a missing month in the certification of a prior conviction exhibit was not judicial testimony, improper vouching, or a due-process violation. The court also held that the unpreserved claim did not satisfy Idaho’s fundamental-error standard because the record showed neither judicial bias nor prejudice. The opinion cautioned that similar judicial intervention may create an appearance of partiality.