The Idaho Supreme Court affirmed the conviction and life sentences of Todd Marshall Frandsen on Thursday, rejecting his appeal of a 2023 conviction for two counts of lewd conduct with a minor under sixteen. The court's decision upholds two concurrent life sentences with 20-year fixed terms imposed by a Bannock County district court.
Frandsen, represented by Greg S. Silvey of Silvey Law Office, Ltd., challenged four alleged errors made by the district court during his trial. The Idaho Attorney General's office, represented by John McKinney, successfully defended the conviction before the high court.
The case centers on Frandsen's 2023 conviction by a Bannock County jury for violating Idaho Code Section 18-1508, which criminalizes lewd conduct with a minor under sixteen. District Judge Rick Carnaroli presided over the original trial in Idaho's Sixth Judicial District.
Frandsen's appeal focused on four specific challenges to the trial proceedings. First, he argued that the district court erred in denying his request to dismiss a juror on the third day of trial. The juror in question had remembered that she attended middle school with one of the victims approximately a decade earlier, creating what Frandsen's counsel argued was a conflict of interest that should have resulted in dismissal.
Second, Frandsen challenged the admission of certain text messages exchanged between one of the victims and the victim's mother. His legal team contended that these communications constituted irrelevant hearsay and contained evidence of uncharged conduct that should not have been presented to the jury. Such evidence, they argued, was prejudicial and violated established rules of evidence.
The third challenge involved the testimony of a forensic interviewer who was initially disclosed as a fact witness but later testified as an expert witness for the state. Frandsen's attorneys argued that this change in the witness's role violated procedural rules and denied the defense adequate opportunity to prepare for expert testimony.
Finally, Frandsen argued that his sentence was excessive. The two concurrent life sentences with 20-year fixed terms, he contended, were disproportionate to the crimes committed and exceeded what was necessary to serve the interests of justice.
The Idaho Supreme Court, in an opinion authored by Justice Moeller, systematically addressed each of these challenges and found them without merit. The court's analysis examined the procedural and substantive issues raised by Frandsen's legal team while considering the state's response to each claim.
Regarding the jury dismissal issue, the court likely weighed the potential for bias against the practical considerations of jury selection and the timing of the juror's recollection. The fact that the memory surfaced on the third day of trial presented the district court with a difficult decision about whether the connection to the victim was sufficiently prejudicial to warrant dismissal.
The text message evidence challenge required the court to balance the relevance of the communications against their potential prejudicial impact. Courts must carefully consider whether such evidence helps establish elements of the charged crimes or merely serves to inflame the jury against the defendant.
The expert witness testimony issue involved questions of procedural fairness and whether the defense had adequate notice and opportunity to challenge the forensic interviewer's qualifications and methodology. Such challenges often turn on the timing of disclosures and whether any procedural violations materially affected the defendant's ability to present his defense.
The excessive sentence challenge required the court to review whether the district court properly considered sentencing factors and whether the punishment fit within established guidelines for similar offenses. Life sentences for sex crimes involving minors, while severe, are typically within the range of permissible sentences under Idaho law.
The Idaho Attorney General's office, led by Raúl R. Labrador, successfully defended each aspect of the original trial and sentencing. The state's arguments apparently persuaded the Supreme Court that the district court acted within its discretion on all challenged issues.
The affirmance means Frandsen will continue serving his life sentences with the possibility of parole after serving the 20-year fixed terms. The decision also establishes precedent for how Idaho courts handle similar procedural and evidentiary issues in cases involving crimes against children.
This case reflects the serious nature of crimes against minors and the careful appellate review such cases receive. The Idaho Supreme Court's thorough examination of each challenged issue demonstrates the state's commitment to ensuring both fair trials and appropriate punishment for those convicted of harming children.
The opinion, filed December 19, 2025, represents the final resolution of Frandsen's direct appeal. Any further legal challenges would require extraordinary circumstances or new evidence not available during the original proceedings.
