State of Idaho v. William E. Tramel

IN THE COURT OF APPEALS OF THE STATE OF IDAHO Docket No. 52690 STATE OF IDAHO, ) ) Filed: February 9, 2026 Plaintiff-Respondent, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED WILLIAM E. TRAMEL, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) ) Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada County. Hon. Jonathan Medema, District Judge.

Judgment of conviction and determinate term of six months for felony possession of a controlled substance, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Jason C. Pintler, Deputy Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Kacey L. Jones, Deputy Attorney General, Boise, for respondent. ________________________________________________ Before TRIBE, Chief Judge; GRATTON, Judge; and HUSKEY, Judge ________________________________________________ PER CURIAM William E. Tramel pled guilty to felony possession of a controlled substance, Idaho Code § 37-2732(c). In exchange for his guilty plea, an additional charge was dismissed. Tramel requested a concurrent sentence of two years or a consecutive sentence of six months. The district court sentenced Tramel to a determinate term of six months.1 Tramel appeals, arguing that his sentence is excessive.

This sentence was ordered to run consecutively to the sentences imposed in Tramel’s two other cases.

Although Tramel received the sentence he asked for, he asserts that the district court erred in imposing an excessive sentence. The doctrine of invited error applies to estop a party from asserting an error when his or her own conduct induces the commission of the error. State v. Atkinson, 124 Idaho 816, 819, 864 P.2d 654, 657 (Ct. App. 1993). One may not complain of errors one has consented to or acquiesced in. State v. Caudill, 109 Idaho 222, 226, 706 P.2d 456, 460 (1985); State v. Lee, 131 Idaho 600, 605, 961 P.2d 1203, 1208 (Ct. App. 1998). In short, invited errors are not reversible. State v. Gittins, 129 Idaho 54, 58, 921 P.2d 754, 758 (Ct. App. 1996).

This doctrine applies to sentencing decisions as well as rulings made during trial. State v. Griffith, 110 Idaho 613, 614, 716 P.2d 1385, 1386 (Ct. App. 1986).

Tramel cannot assert error of a decision he invited. Therefore, Tramel’s judgment of conviction and sentence are affirmed.