Justia Idaho Supreme Court Opinion Summaries

In October 2021, Gregg Alan Hoover was arrested and cited for misdemeanor domestic battery. In April 2022, the State amended the charge to a felony under Idaho Code section 18-918(5), citing Hoover’s March 2022 conviction for felony domestic battery with traumatic injury. Hoover moved to dismiss the felony enhancement, arguing that the March 2022 conviction occurred after the October 2021 incident. The district court agreed and dismissed the felony enhancement, reasoning that the enhancement could not apply because the conduct in question occurred before the March 2022 conviction.The State appealed, arguing that the enhancement provision only requires a prior felony conviction within fifteen years of the subsequent conviction, not that the criminal conduct must occur after the prior conviction. The Idaho Court of Appeals issued an unpublished decision, and Hoover petitioned for review, which the Idaho Supreme Court granted.The Idaho Supreme Court reviewed the case de novo and concluded that the plain language of Idaho Code section 18-918(5) does not impose a timing requirement related to the criminal conduct. The statute enhances a charge if a defendant has a prior felony conviction and is found guilty of a further violation within fifteen years, regardless of when the conduct occurred. The Court reversed the district court’s dismissal of the felony enhancement and remanded the case for further proceedings. View "State v. Hoover" on Justia Law

In 2019, Colby James Bray died while in the custody of the Idaho Department of Juvenile Corrections (IDJC). His parents, Jeffrey and Michelle Bray, acting as personal representatives of his estate, filed a wrongful death suit in federal court one day before the two-year statute of limitations expired. They later voluntarily dismissed the federal case and refiled in state court nearly three years after Colby's death. The defendants moved for summary judgment, arguing the claims were time-barred by the two-year statute of limitations. The district court granted the motions and dismissed the complaint with prejudice.The Brays appealed, arguing that Idaho Code section 5-234 and 28 U.S.C. section 1367(d) tolled the statute of limitations. The district court had concluded that section 5-234 did not toll the time for filing the state complaint and that section 1367(d) did not apply to IDJC due to Eleventh Amendment immunity. The court also awarded costs and attorney fees to the defendants.The Supreme Court of Idaho affirmed the district court's ruling that section 5-234 did not toll the statute of limitations. It also agreed that the claims against Meacham and the Individual Defendants were time-barred under section 1367(d) because the Brays did not file within 30 days after the federal court dismissed those claims. However, the court found that section 1367(d) did toll the time for filing the complaint against IDJC, but IDJC was immune from the claims under Idaho Code section 6-904B(5). The court upheld the district court's award of attorney fees and costs to the defendants and awarded attorney fees and costs on appeal to the respondents. View "Bray v. ID Dept of Juvenile Corrections" on Justia Law

In 2021, Aaron Von Ehlinger, a first-year member of the Idaho State House of Representatives, was accused of rape by J.V., a legislative intern. They had dinner together and later went to Von Ehlinger’s apartment, where J.V. alleged that he sexually assaulted her. Von Ehlinger claimed the encounter was consensual. J.V. reported the incident, and a forensic nurse, Ann Wardle, conducted a sexual assault examination, documenting J.V.'s account and collecting evidence. Von Ehlinger was charged with rape and sexual penetration by use of a foreign object.The case proceeded to trial in April 2022 in the District Court of the Fourth Judicial District of Idaho. During the trial, Wardle testified about J.V.'s statements, which were admitted despite objections from Von Ehlinger’s defense on hearsay grounds. J.V. testified briefly but left the courtroom before cross-examination, leading the court to strike her testimony. The jury found Von Ehlinger guilty of rape but acquitted him of the second charge. The district court denied Von Ehlinger’s motion for acquittal or a new trial and sentenced him to 20 years in prison, with 8 years fixed.The Idaho Supreme Court reviewed the case. Von Ehlinger argued that his Sixth Amendment rights were violated by the admission of Wardle’s testimony and that the district court erred in allowing a leading question. The court found that Von Ehlinger failed to demonstrate that the admission of Wardle’s testimony was fundamental error, as his counsel’s failure to object could have been a tactical decision. The court also determined that any error in allowing the leading question was harmless, as Wardle did not answer the question directly. The court affirmed the judgment of conviction, concluding that there was sufficient evidence to support the jury’s verdict. View "State v. Von Ehlinger" on Justia Law

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court's denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith's motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and inventory search of his vehicle were reasonable and conducted according to police procedures. Smith was subsequently convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the State did not meet its burden to show that the police officer's decision to impound Smith's vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. As a result, the evidence obtained from the search was inadmissible, leading to the vacating of Smith's conviction. View "State v. Smith" on Justia Law

Interfaith Sanctuary Housing Services, Inc. (IFS) applied for a conditional use permit (CUP) to operate a large-scale low-barrier shelter home in Northwest Boise. The Planning and Zoning Commission (PZC) initially denied the application, citing concerns about compatibility with the neighborhood, undue burden on public facilities, adverse effects on nearby properties, and insufficient information on mitigating adverse impacts. IFS appealed to the Boise City Council, which reversed the PZC’s decision and granted the CUP, imposing 30 conditions of approval. The Veterans Park Neighborhood Association, Inc. (VPNA) sought reconsideration, which was denied, and then petitioned the district court for judicial review.The district court upheld the City Council’s decision, finding no error in the Council’s actions. VPNA appealed to the Idaho Supreme Court, arguing that the City Council’s decision was arbitrary and capricious, based on unlawful procedure, and that the Council’s reasoned statement was inadequate under the Local Land Use Planning Act (LLUPA).The Idaho Supreme Court found that the City Council’s decision was arbitrary and capricious and based on unlawful procedure because the PZC’s determination that the CUP could not be conditioned into compliance with the CUP criteria was not an error. The Court also found that the City Council’s reasoned statement was conclusory and failed to adequately resolve pertinent factual disputes, thus violating LLUPA and depriving VPNA of due process. The Court concluded that VPNA demonstrated a prejudice to its substantial rights.The Idaho Supreme Court reversed the district court’s decision and remanded the case with instructions to invalidate the City Council’s approval of the CUP. VPNA was awarded costs but not attorney fees on appeal. View "Veterans Park Neighborhood Association, Inc. v. City of Boise" on Justia Law

Manuel and Melissa Rose purchased property from the F & M Martino Family Trust, with Fred and Michelle Martino acting as trustees. The warranty deed did not reference a previously recorded Boundary Line Agreement (BLA) that established a barbed wire fence as the boundary between the Roses' property and the neighboring property owned by Donald and Marylee Meliza. The Melizas later obtained a survey showing the fence was on the Roses' property and filed a quiet title action for the disputed strip of land. The Roses sought defense from the Martinos, who refused, leading the Roses to file a third-party action for breach of warranty of title and breach of the covenant of seisin.The district court granted summary judgment in favor of the Martinos, finding that the BLA was a "matter of record" and thus excluded from the warranty deed. The court also denied the Martinos' request for attorney fees. The Roses appealed the summary judgment decision, and the Martinos cross-appealed the denial of attorney fees.The Supreme Court of Idaho reversed the district court's summary judgment decision, holding that the warranty deed's language was clear and unambiguous and did not exclude the BLA. The court found that the Martinos breached the covenant of seisin by not owning the entire property described in the deed and breached the warranty of title by failing to defend the Roses in the quiet title action. The court affirmed the district court's decision to deny attorney fees to the Martinos, as the case did not involve a commercial transaction and the warranty deed did not contain an attorney fee provision. The case was remanded for further proceedings consistent with the Supreme Court's opinion. The Roses were awarded costs on appeal. View "Rose v. Martino" on Justia Law

Daniel Ruiz Ortiz was convicted of second-degree murder and violating a no contact order (NCO). Ortiz appealed, arguing that the district court erred in denying his motion to suppress evidence obtained during a warrantless search of his home and a subsequent search conducted with a warrant. The district court relied on the Idaho Supreme Court's decision in State v. Rebo, which held that Ortiz lacked Fourth Amendment standing to challenge the warrantless search because the NCO prohibited him from being within 300 feet of the residence.The district court found that Ortiz did not have standing to challenge the search, as he was prohibited by the NCO from being near the home. Ortiz's case proceeded to a jury trial, where he was found guilty of second-degree murder and violating the NCO. He was sentenced to life in prison, with the first thirty years fixed. Ortiz appealed the denial of his motion to suppress, arguing that the Rebo decision should be overruled or that his case was distinguishable from Rebo.The Idaho Supreme Court reviewed the case and declined to overrule Rebo, finding that Ortiz failed to demonstrate that the decision was manifestly wrong. The court also found that while Ortiz's case was factually distinguishable from Rebo, he still lacked Fourth Amendment standing to challenge the warrantless search. The court held that Ortiz did not have a reasonable expectation of privacy in the home due to the NCO and that law enforcement's entry into the home was justified by exigent circumstances, as they were concerned for Ruiz's safety.The Idaho Supreme Court affirmed the district court's decision, concluding that Ortiz did not have standing to challenge the warrantless search of his home. View "State v. Ortiz" on Justia Law

Dustin Clover sustained injuries while removing irrigation drip tape from a seed field while working for Crookham Company in 2018. Clover filed a complaint against Crookham, alleging that his injuries fell within an exception to the exclusive remedy rule under the Worker’s Compensation statutes, which allows for a separate civil action if the employer commits an act of “willful or unprovoked physical aggression.” Crookham moved for summary judgment, arguing that Clover failed to provide evidence supporting his claim. The district court agreed and granted summary judgment in favor of Crookham. Clover’s motion for reconsideration was also denied, leading to this appeal.The district court of the Third Judicial District of Idaho found that Clover’s injuries occurred during the course of his employment and were covered by worker’s compensation. The court concluded that Clover did not present sufficient evidence to show that Crookham’s actions fell under the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The court noted that there were no prior incidents or complaints about the drip tape lifter’s safety and that Crookham had used the equipment for nine seasons without injury.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The court held that Clover failed to demonstrate that Crookham consciously disregarded knowledge that the drip tape lifter was unsafe. The court also found that the district court did not abuse its discretion in excluding certain evidence and denying Clover’s motion for reconsideration. The court concluded that Clover did not present new facts sufficient to raise a genuine dispute of material fact. Consequently, the district court’s grant of summary judgment and denial of the motion for reconsideration were affirmed. Crookham was awarded costs as the prevailing party on appeal. View "Clover v. Crookham Company" on Justia Law

BrunoBuilt, Inc. contracted with William and Amy Dempsey to build a home in the Boise Foothills. With the help of insurance agent Randy L. Richardson, BrunoBuilt purchased a Tailored Protection Policy (TPP) from Auto-Owners Insurance Company, which included "Builders' Risk" coverage. The policy excluded damage caused by landslides. In 2016, the Dempsey project was not included in the TPP renewal, allegedly due to Richardson's negligence. Shortly after, the nearly completed Dempsey home was damaged by a landslide. BrunoBuilt sued Richardson and Auto-Owners, claiming Richardson negligently failed to advise about landslide coverage and failed to renew the Dempsey project. BrunoBuilt also claimed Auto-Owners was vicariously liable for Richardson's negligence.The District Court of the Fourth Judicial District of Idaho granted summary judgment in favor of Auto-Owners, concluding Richardson was not acting as Auto-Owners' agent and that the policy excluded landslide damage. BrunoBuilt appealed.The Supreme Court of Idaho reviewed the case and found that the district court erred in granting summary judgment. The court held that the 2015 policy, which excluded only naturally occurring landslides, might still apply because Auto-Owners did not provide the required notice of the reduction in coverage in the 2016 policy, which excluded both naturally occurring and human-caused landslides. The court also determined that Auto-Owners bore the burden of proving the applicability of the landslide exclusion. The case was reversed and remanded for further proceedings to determine whether the 2015 policy's coverage continued and whether Richardson was acting as Auto-Owners' agent when he failed to renew the policy. The court did not award attorney fees to either party. View "BrunoBuilt, Inc. v. Auto-Owners Insurance Company" on Justia Law

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law