Justia Idaho Supreme Court Opinion Summaries

A citizens’ group challenged the official ballot statements prepared by the Idaho Secretary of State and Attorney General for the 2026 general election, which would accompany Proposition One, the Reproductive Freedom and Privacy Act. The group argued that the statements describing the effect of a “yes” or “no” vote were unclear, misleading, and exceeded the statutory authority given to the officials, as they characterized both the proposed law and existing Idaho law rather than simply stating the effect of each vote.Previously, the Idaho Supreme Court had considered similar issues regarding other ballot materials for the same initiative in Idahoans United for Women & Families v. Labrador, 175 Idaho 708, 570 P.3d 1137 (2025), where it directed revisions to the short ballot title and the fiscal impact statement to ensure substantial compliance with statutory requirements. After the initiative qualified for the ballot, the officials prepared the contested Yes/No Effect Statements and distributed them to county clerks. The group’s objections were not resolved through negotiation, leading to the current original action before the Idaho Supreme Court.The Supreme Court of the State of Idaho concluded that the group had standing under its relaxed standing doctrine, found it had original jurisdiction to issue writs of mandamus and prohibition, and applied the standard of substantial compliance to the ballot statements. The court held that both the “yes” and “no” statements failed to clearly and concisely communicate the effect of a vote, as required by Idaho Code section 34-1810(1)(b). The court granted writs of prohibition and mandamus, prohibited use of the challenged statements, and ordered the officials to prepare new, compliant statements by a set deadline. The request for a writ of certiorari was denied as duplicative, and no attorney fees were awarded. View "Idahoans United v. McGrane" on Justia Law

Several parcels of land along the shore of Priest Lake, Idaho, were originally owned by William and Mary Taylor and later subdivided and conveyed to various parties, including the Byrds, the McCray Living Trust, and the Coffeys. The dispute centers on a strip of land between the parcels now owned by the Byrds and the Trust and the lake’s ordinary high water mark. The Byrds and the Trust argued their deeds conveyed property extending to the lake’s shoreline, and thus included littoral rights. The Coffeys contended the deeds did not reach the shoreline and that they held title to the disputed strip.After a prior administrative dispute over a dock permit, the Byrds and the Trust initiated quiet title and declaratory judgment actions in the District Court of the First Judicial District of Idaho, Bonner County. The Coffeys counterclaimed, also seeking a declaration of ownership and alleging civil trespass. Following a bench trial, the district court found the deeds ambiguous, looked to extrinsic evidence, and concluded the deeds did not convey land up to the shoreline. The court awarded the disputed strip and littoral rights to the Coffeys, determined the Byrds and the Trust had trespassed, and awarded damages and attorney fees to the Coffeys.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court erred in its findings and in the legal standards applied. The Supreme Court held that while the district court correctly found the deeds ambiguous, it used the wrong burden of proof—a clear and convincing evidence standard—when deciding the parties’ competing declaratory judgment claims. The correct standard was a preponderance of the evidence. Because the district court did not analyze the evidence under the appropriate standard, the Supreme Court reversed the decision, vacated the judgment, and remanded the case for further proceedings using the proper burden of proof. The Supreme Court declined to award attorney fees on appeal. View "Byrd v. Coffey" on Justia Law

A dispute arose between two parties over a residential lease agreement in Mountain Home, Idaho, which included an option to purchase the property after the underlying Wells Fargo mortgage was satisfied. The lessee paid $8,000 for the purchase option and began residing at the property. Eighteen months later, the lessee filed for Chapter 7 bankruptcy, listing the lessor as a creditor and rent as an expense but denying any legal or equitable interest in real property and failing to disclose the lease agreement or the purchase option in the bankruptcy schedules. The bankruptcy trustee closed the case without distributing any assets, and the lessee received a discharge of debts. Four years after discharge, the lessee attempted to exercise the purchase option, but the lessor refused.The lessee filed suit in the District Court of the Fourth Judicial District, seeking specific performance and declaratory relief, while the lessor counterclaimed for breach of contract. Both parties moved for summary judgment. The district court initially denied both motions, finding factual disputes, and declined to apply judicial estoppel. Upon reconsideration, the district court ruled for the lessor, holding that the lessee’s claims were barred by judicial estoppel and, in the alternative, that the lessee lacked standing because the undisclosed purchase option remained property of the bankruptcy estate. The district court denied the lessee’s request to stay the proceedings to reopen the bankruptcy case.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s judgment, holding that the lessee lacked standing to enforce the purchase option. The court reasoned that the purchase option was property of the bankruptcy estate, was not properly disclosed in the bankruptcy schedules, and thus remained with the estate after the bankruptcy case closed. Only the bankruptcy trustee, not the lessee, had standing to enforce the option. Costs on appeal were awarded to the lessor. View "Conger v. Clark" on Justia Law

The case arose from a single incident in which the petitioner forcibly took a 2000 BMW from its owner at gunpoint during a high-speed chase through Idaho County. He was charged with multiple offenses, including grand theft of an automobile and armed robbery, both relating to the same act of taking the BMW. The petitioner pleaded guilty to several charges pursuant to a plea agreement, and the district court sentenced him to consecutive terms, including for both grand theft and armed robbery.After his conviction was affirmed by the Idaho Court of Appeals on direct appeal (where he did not raise a double jeopardy argument), the petitioner filed for post-conviction relief in the District Court of the Second Judicial District. He argued that his trial counsel was ineffective for not raising a double jeopardy objection to being convicted and sentenced for both offenses stemming from the same conduct. The district court summarily dismissed his petition, concluding that the double jeopardy claim was both procedurally barred and, on the merits, that grand theft was not a lesser included offense of armed robbery under either the Blockburger test or Idaho’s pleading theory. The Idaho Court of Appeals affirmed.The Supreme Court of the State of Idaho reviewed the case and held that, under the Idaho Constitution’s double jeopardy provision and Idaho’s pleading theory, grand theft as charged was a lesser included offense of the armed robbery charge because both counts were based on the same act of taking the same car from the same victim. The Court clarified that the pleading theory, not the strict elements (Blockburger) test, governs such double jeopardy claims under Idaho law. As a result, the Court vacated the judgment, reversed the district court’s order granting summary disposition, and remanded the case for further proceedings, concluding that the petitioner established a prima facie case of ineffective assistance of counsel. View "Sedillo v. State" on Justia Law

The State of Idaho sought to build a highway interchange through property owned by Triple Crown Development, LLC. Triple Crown and several related entities, all controlled by Lance Thueson, claimed business damages under Idaho Code section 7-711(2) due to the condemnation. Americrete Land Holding LLC owned land adjacent to the condemned property, and the other intervenor entities conducted business on the Americrete property. Thueson asserted that he intended for River Rock Sand & Gravel LLC to mine gravel on the condemned property, with Thueson Construction, Inc. hauling the material to a concrete plant operated by G&B Redi-Mix on Americrete’s property. However, no mining permits were obtained, and operations never commenced on the condemned property.After the State condemned a portion of Triple Crown’s property and initiated proceedings in the District Court of the Third Judicial District, Canyon County, the parties stipulated to property value and allowed the related entities to intervene. The State moved for summary judgment on the business damages claim, arguing neither Triple Crown nor the intervenors qualified for business damages because Triple Crown did not operate a business on the condemned property and the intervenors' businesses were not located on land owned by Triple Crown. The district court granted summary judgment, dismissing the business damages claims, and denied a motion for reconsideration.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Court held that, under section 7-711(2), only the fee title owner of the condemned property may claim business damages for a business operating on that property or on adjoining land owned by the same owner. Beneficial or joint venture interests are insufficient to qualify as ownership under the statute. The Court also denied the State’s request for attorney fees, finding the appeal was not frivolous or without foundation. View "STATE v. TRIPLE CROWN DEVELOPMENT, LLC" on Justia Law

The case involves a defendant who, while under the influence of alcohol and oxycodone, intentionally crashed his vehicle into a minivan carrying a family of six, causing bodily harm to each member. The State charged the defendant with six counts of aggravated battery, four counts of injury to a child, and one count of misdemeanor driving under the influence. After a mental health evaluation and a period of commitment, the defendant was found fit to proceed and pleaded guilty to all charges.The Third Judicial District Court of Idaho sentenced the defendant to consecutive and concurrent terms for the various counts and orally pronounced that he would receive credit for 477 days of time served. However, the written judgment of conviction ambiguously applied the 477 days of credit to each count, potentially multiplying the credit. The State filed a motion to clarify the sentence, and the district court, at a hearing held without the defendant's presence, clarified its intent that the credit for time served should total 477 days across all counts, not per count. The district court rescinded the original written judgment and issued a superseding judgment of conviction reflecting this intent.The Idaho Court of Appeals affirmed the district court’s amended judgment. The defendant sought review, arguing the district court lacked jurisdiction and authority to issue the amended judgment after the original sentence had been imposed. The Supreme Court of the State of Idaho held that the district court had jurisdiction and authority under Idaho Criminal Rule 35(a) to amend the judgment to resolve the ambiguity between the oral pronouncement and the written judgment. However, the Supreme Court determined that the error was in conducting the resentencing hearing without the defendant’s presence. Accordingly, the Supreme Court vacated the amended judgment and remanded the case for resentencing in the defendant’s presence. View "State v. Mooney" on Justia Law

A certified nurse assistant in Idaho suffered significant injuries, including fractures and tendon tears, after slipping and falling in her employer’s parking lot while working. As a result of her injuries, she underwent three surgeries and experienced ongoing pain and physical limitations, which restricted her from returning to her prior position as a CNA. She was able to continue employment at the same facility in a less physically demanding role as an activities director. Multiple medical and vocational experts concluded that her injuries limited her to light-duty work and that she lost access to a significant portion of the labor market in which she previously participated.After filing a worker’s compensation claim, her case was heard by a referee for the Idaho Industrial Commission. The referee found a 4% permanent physical impairment, a figure not in dispute, but the parties disagreed on her permanent partial disability rating. The claimant sought a 34% rating based on vocational evidence showing a substantial loss in labor market access, while the employer argued for 17%. The Commission ultimately adopted the referee’s recommendation of a 20% rating, discounting the claimant’s evidence as overinflated and expressing skepticism about her future employment limitations, in part because her treating physician did not formally issue medical restrictions.On appeal, the Supreme Court of the State of Idaho set aside the Commission’s order. The Court held that the Commission erred by failing to accept unrefuted evidence supporting the 34% disability rating, by improperly requiring the claimant’s functional capacity assessment to be formally endorsed by her treating physician, and by incorrectly focusing on her retention of her current job rather than her overall access to the labor market. The Court found the record supported the claimant’s proposed 34% rating and concluded that the Commission’s order should be set aside. View "WHITELEY v. LIFE CARE CENTERS OF AMERICA" on Justia Law

A dispute arose among siblings following the death of their sister, who had lived with their father for over a decade. After her passing, one sibling was appointed as the personal representative of her estate and became concerned about the disposition of certain assets, including personal property that may have belonged to the decedent. Another sibling, who had been both trustee of their father's trust and later personal representative of their father’s estate, was alleged to have sold or otherwise disposed of the decedent’s property, including through an auction.The personal representative first sought the return of assets or their value in probate court, but after the respondents denied possessing such assets, the petition was dismissed without prejudice by the magistrate court. Nearly two years later, the personal representative filed a complaint with similar allegations. The magistrate court granted a motion to dismiss, concluding that the claims were barred by the three-year statute of limitations applicable to actions for conversion of personal property. The personal representative appealed to the District Court of the Seventh Judicial District, which affirmed the magistrate court’s dismissal.On further appeal, the Supreme Court of the State of Idaho reviewed whether it had subject matter jurisdiction and whether the lower courts erred in dismissing the complaint as untimely. The Court held that each civil proceeding within a probate matter is independent and a final judgment on any such claim is appealable even if the probate remains open. It also held that the three-year statute of limitations applied to the claims, which were based on the alleged wrongful taking of personal property. The request for attorney fees by the respondent was denied due to lack of supporting argument. The Supreme Court affirmed the district court’s decision. View "BOWEN v. PENROD" on Justia Law

After being arrested for domestic battery against S.O., Nicholas James Orr was subject to a criminal no contact order prohibiting communication with S.O. Despite this order, Orr repeatedly called S.O. from jail and made statements that included urging her to alter her testimony, suggesting she say the incident “didn’t happen,” and implying that her actions could “fix” his legal troubles. The State charged Orr with intimidating a witness under Idaho Code section 18-2604(3), as well as multiple violations of the no contact order.The District Court of the Sixth Judicial District denied Orr’s motion to dismiss the witness intimidation charge. Orr had argued that the statute was facially overbroad under the First Amendment and unconstitutional as applied to his conduct, asserting that the “by any manner” language of the statute criminalized protected speech, including his attempts to persuade S.O. to provide more information or clarify her statements. The district court concluded that the statute did not infringe on protected speech, as it targeted attempts to influence or prevent truthful testimony, and that Orr’s conduct could be interpreted as seeking perjury.Orr entered a conditional guilty plea to the intimidation charge, reserving the right to appeal the denial of his motion to dismiss. The Supreme Court of the State of Idaho reviewed the case de novo and affirmed the district court’s decision. The Idaho Supreme Court held that Idaho Code section 18-2604(3) is not unconstitutionally overbroad because it prohibits speech integral to criminal conduct, such as suborning perjury, which is not protected by the First Amendment. The court also held that, as applied to Orr, the statute was constitutional because his statements could reasonably be interpreted as attempts to convince S.O. to testify untruthfully. The court affirmed the denial of the motion to dismiss. View "State of Idaho v. Orr" on Justia Law

While receiving unemployment benefits, the claimant worked part-time for Terrace Home Health Boise, LLC and reported her earnings to the Idaho Department of Labor. After an audit, the Department determined that she had underreported her earnings in four weekly certifications, resulting in an overpayment of $228. The claimant explained the discrepancies by noting differences in pay periods and her method of calculating wages, as well as possible reporting mistakes due to not recognizing partial hour increments. Terrace Home Health initially reported some errors, but those were subsequently corrected. The Department concluded that the overpayment was not intentional and did not assess penalties, but demanded repayment and advised the claimant of her right to appeal and request a waiver.Following the Department’s determination and subsequent denial of her waiver request, the claimant appealed to the Department’s Appeals Bureau, which held a telephonic hearing. The claimant asserted that the errors were caused by her employer’s reporting and objected to the deduction from her benefit payment. The appeals examiner found that the overpayment resulted from the claimant’s own misreporting and denied her appeal. The claimant further appealed to the Idaho Industrial Commission, reiterating her arguments and raising concerns about the fairness of the hearing. The Commission concluded that the overpayment was due to her error, not Department or employer error, making her ineligible for a waiver, and found no evidence that the hearing was conducted improperly.Upon review, the Supreme Court of the State of Idaho affirmed the Industrial Commission’s decision. The Court held that the claimant forfeited any assignment of error because her appellate briefing failed to comply with Idaho Appellate Rule 35(a)(6), requiring argument and citations to legal authority and the record. As a result, the Commission’s denial of the waiver and affirmation of the repayment obligation was upheld. View "PHELPS v. COMMUNITY HEALTH CLINICS, INC." on Justia Law