The Idaho Court of Appeals has overturned the stalking conviction of Montrez Lushon Mayberry, ruling that there was not enough evidence to prove he engaged in a "course of conduct" as defined by state law. The decision, filed on June 18, 2026, affects Mayberry's legal standing and highlights the complexities of stalking laws in Idaho.
This ruling is significant because it clarifies the legal definition of stalking in Idaho, particularly regarding what constitutes "nonconsensual contact." The court's decision may influence future cases involving similar charges and the interpretation of stalking statutes.
Background
Montrez Lushon Mayberry was charged with first-degree stalking and two counts of domestic battery with traumatic injury. The charges stemmed from incidents involving his former partner, M.F., between March and June 2023. During this time, there was an active no-contact order in place between the two due to prior incidents of violence.
The state alleged that Mayberry repeatedly contacted M.F. in violation of the no-contact order, which caused her significant emotional distress. The prosecution argued that his actions, including physical assaults and attempts to control M.F. during their relationship, constituted stalking. Mayberry pleaded not guilty, and the case went to trial.
The Ruling
The Idaho Court of Appeals ruled that the evidence presented at trial was insufficient to support the stalking conviction. The court stated, "the State failed to sustain its burden of proving Mayberry engaged in a course of nonconsensual contact pursuant to I.C. § 18-7906(2)(c)." The judges emphasized that the term "contact" in the context of the stalking statute does not include physical violence, which is already addressed by other laws.
As a result, the court vacated Mayberry's conviction for first-degree stalking, while affirming the conviction for domestic battery with traumatic injury. The court also noted that since the stalking conviction was overturned, it was unnecessary to address other arguments related to the admission of evidence regarding the no-contact order.
Impact
This ruling has significant implications for how stalking laws are interpreted in Idaho. By clarifying that physical violence does not fall under the definition of "nonconsensual contact" for stalking charges, the court may have narrowed the scope of what constitutes stalking. This could affect future cases where physical abuse is involved, as it suggests that such behavior should be prosecuted under different statutes rather than under stalking laws.
The decision may also influence how prosecutors approach cases involving domestic violence and stalking, potentially requiring them to provide more evidence of non-violent forms of contact to secure a conviction for stalking. This ruling could lead to a reevaluation of how victims of domestic violence are protected under Idaho law.
What's Next
Mayberry's case has been remanded to the lower court for further proceedings consistent with the appellate court's ruling. It is unclear if the state will seek to appeal this decision or pursue additional charges against Mayberry. Details were not available in the court filing regarding any related cases or potential appeals.