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) THIS IS AN UNPUBLISHED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.

1
This sentence was ordered to run consecutively to the sentences imposed in Tramel’s two
other cases.

1
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.

2