Justia Idaho Supreme Court Opinion Summaries

Sherry Cole filed a formal complaint against Rocky Mountain Power (RMP) alleging she had been overbilled due to her power meter being cross-connected with her neighbor’s. Initially, an RMP employee confirmed the cross-connection and credited her account with $1,256.45. However, subsequent tests revealed no cross-connection, leading RMP to remove the credit and instead apply a $450 credit for the inconvenience. Cole then filed a formal complaint with the Idaho Public Utilities Commission, which dismissed her complaint due to lack of evidence of overcharging. Cole's motion for reconsideration was also denied.The Idaho Public Utilities Commission reviewed Cole’s complaint and RMP’s response, which included calculations of her energy usage and an affidavit from an investigator who found no cross-connection. The Commission dismissed Cole’s complaint, finding no evidence of overcharging, and denied her petition for reconsideration, stating she failed to demonstrate the dismissal was unreasonable or unlawful. Cole appealed to the Supreme Court of Idaho, asserting multiple errors.The Supreme Court of Idaho affirmed the Commission’s decisions. The Court found that the Commission’s findings were supported by substantial and competent evidence, including the investigator’s analysis and the results of two breaker tests. The Court also held that Cole’s constitutional arguments were waived as they were raised for the first time on appeal and were not supported by sufficient legal authority. Additionally, the Court ruled that pro se litigants are not entitled to attorney fees, and since Cole appeared pro se and did not prevail, she was not awarded attorney fees. View "Cole v. Idaho Public Utilities Commission" on Justia Law

Elizabeth Corey Raber (Mother) and Michael Robert Raber (Father) married in 2019 in Texas and had one child. They moved to Coeur d’Alene, Idaho, in June 2020. Their relationship involved significant conflict, including a domestic dispute in June 2020 and a felony domestic battery charge against Father in December 2021, which was later dismissed. They separated, and Mother filed for divorce in January 2022, requesting joint legal and physical custody but primary physical custody and permission to relocate to Texas with the child. Father initially sought sole custody but later requested joint custody with equal time.The magistrate court ordered a Parenting Time Evaluation (PTE), which recommended joint legal custody with Mother having sole decision-making authority over schooling and routine medical care. The PTE also recommended that Mother have primary physical custody and be allowed to relocate to Houston. The magistrate court proposed two custody options: one where the child would stay in Idaho with a week-on/week-off schedule, and another where the child would fly between Idaho and Texas every two weeks. The court entered a judgment based on the second option after Mother relocated to Texas.The Supreme Court of Idaho reviewed the case and found that the magistrate court failed to consider all relevant factors, including the impact of the child traveling 2,000 miles every two weeks and the effect on the child’s education and stability. The court held that the magistrate court abused its discretion by not making a specific determination regarding the best interests of the child. The judgment was vacated, and the case was remanded for further proceedings to properly analyze the best interests of the child and consider all relevant factors. The court declined to award costs on appeal, as there was no prevailing party. View "Raber v. Raber" on Justia Law

The case involves Danielle Radue, who appealed her conviction for first-degree murder following the death of her nine-week-old son, D.M. On May 11, 2020, Radue called 911, reporting that D.M. was not breathing. She initially claimed D.M. was in a swing and possibly choking. Later, she admitted to putting D.M. on the ground harder than intended, causing his head to strike the floor. Medical examinations revealed D.M. had a fractured skull and brain bleeding, leading to his death. Radue was indicted for first-degree murder and entered a conditional guilty plea, preserving her right to appeal several pretrial rulings.The District Court of the Fourth Judicial District of Idaho reviewed the case. Radue challenged several pretrial rulings, including the exclusion of expert testimony on her mental state, the admission of prior acts of violence under Rule 404(b), the prohibition of cross-examining the State’s medical expert about a prior case, the denial of funds for an expert on false confessions, the use of the term "victim" at trial, and the limitation on peremptory challenges due to COVID-19.The Idaho Supreme Court reviewed the case. It affirmed the district court’s exclusion of Dr. Cirino’s testimony, agreeing it was an attempt to present an insanity defense, which is not permissible under Idaho law. The court also upheld the admission of prior acts of violence, finding them relevant to the issue of willfulness. The court ruled that the argument regarding cross-examining the State’s medical expert was not preserved for appeal. It found no abuse of discretion in denying funds for an expert on false confessions, as the money judge reasonably concluded there was no coercion. The court also upheld the use of the term "victim," noting it did not inherently imply guilt. Lastly, the court found the challenge to the limitation on peremptory challenges moot following its decision in State v. Harrell, which upheld the reduction due to the pandemic. The Idaho Supreme Court affirmed the district court’s orders and Radue’s conviction. View "State v. Radue" on Justia Law

Julene and William Dodd sued their attorney, Rory Jones, for legal malpractice after he missed the statute of limitations deadline for filing their medical malpractice lawsuit. The Dodds needed to prove that their original medical malpractice case had merit and that they would have won if Jones had filed on time. However, the district court struck the testimony of the Dodds’ experts, which was key to establishing the viability of their medical malpractice claim. The court found that the disclosures were untimely and that the experts failed to properly establish knowledge of the local standard of care, a foundational requirement of Idaho law. As a result, the Dodds’ legal malpractice claim was dismissed, and the court granted summary judgment in favor of Jones.The Dodds appealed to the Supreme Court of Idaho, arguing that the district court erred by ruling that Jones was not judicially estopped from arguing that no medical malpractice occurred and by excluding their expert testimony. They also raised claims of judicial bias. The Supreme Court of Idaho found that Jones could not be judicially estopped from claiming that no medical malpractice occurred because he was not a party in the original medical malpractice case but was representing the Dodds. The court also upheld the district court’s exclusion of the Dodds’ expert testimony, finding that the experts did not demonstrate familiarity with the local standard of care in Nampa, Idaho, at the time of the alleged malpractice.The Supreme Court of Idaho affirmed the district court’s judgment, concluding that the Dodds failed to establish an essential element of their legal malpractice case. The court also awarded attorney fees to Jones under Idaho Appellate Rule 11.2, finding that the appeal was pursued frivolously and without foundation, and sanctioned the Dodds’ attorney, Angelo Rosa, for his conduct during the appeal. View "Dodd v. Jones" on Justia Law

Lea Anne Eaton was arrested and charged with felony burglary under Idaho Code section 18-1401 for using discarded Walmart receipts to return stolen items for a refund. Shortly after her charge, a new statute, Idaho Code section 18-1401A, creating a misdemeanor offense of "commercial burglary," became effective. Eaton filed a motion to reduce her felony charge to the new misdemeanor charge, which the district court denied. Eaton entered a conditional guilty plea, reserving her right to appeal the denied motion, and was sentenced to a unified ten-year sentence with four years fixed. She subsequently filed motions for reconsideration and to correct an illegal sentence, both of which were denied. Eaton appealed these decisions.The Idaho Court of Appeals upheld Eaton's conviction and sentence. Eaton then filed a Petition for Review, which the Idaho Supreme Court granted. The Supreme Court reviewed whether the district court erred in denying Eaton's motion to reduce her charge and her motion to correct an illegal sentence.The Idaho Supreme Court held that the commercial burglary statute, Idaho Code section 18-1401A, was not retroactive and did not apply to Eaton's conduct, which occurred before the statute's enactment. The Court found that the statute created a new offense with distinct elements from the general burglary statute and did not amend the penalties for general burglary. Therefore, Eaton was properly charged and convicted under the general burglary statute, Idaho Code section 18-1401. The Court also held that Eaton's sentence was not illegal, as she was not entitled to the lesser penalty under the commercial burglary statute. Consequently, the Idaho Supreme Court affirmed the district court's judgment and the denial of Eaton's Rule 35(a) motion. View "State v. Eaton" on Justia Law

In April 2021, a confidential informant (CI) working for the Blaine County Sheriff’s Office was introduced to Kelly D. Webb. The CI, at the request of the Sheriff’s Office, attempted to purchase methamphetamine from Webb. Webb sold the CI more than 28 grams of methamphetamine on two occasions, leading to his indictment by a grand jury for two counts of felony trafficking in methamphetamine. Webb pleaded not guilty and filed a motion in limine to present a defense of "charge entrapment," arguing that he was induced by law enforcement to sell a larger quantity of drugs than he intended. The district court denied his motion, and Webb entered a conditional guilty plea, reserving his right to appeal the denial.The District Court of the Fifth Judicial District of Idaho reviewed Webb's motion and held hearings on the matter. The court determined it had the authority to recognize charge entrapment as an extension of the common law defense of entrapment but ultimately declined to do so. The court noted that charge entrapment is a minority position in other jurisdictions and is typically associated with the Federal Sentencing Guidelines, which differ from Idaho’s mandatory minimum sentencing laws. Webb was sentenced to a unified sentence of 7 years, with 3 years fixed, and a $10,000 fine, which are the mandatory minimums for trafficking in methamphetamine.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's decision. The court declined to recognize the defense of charge entrapment, noting that Idaho’s traditional entrapment defense is intended to protect innocent individuals from being induced to commit crimes, which did not apply to Webb’s case. The court also found that the rationale behind charge entrapment in federal cases, which is based on the Federal Sentencing Guidelines, does not apply to Idaho’s mandatory minimum sentencing scheme. Therefore, the court upheld the district court's denial of Webb's motion in limine. View "State v. Webb" on Justia Law

In this case, the paternal grandmother, Natasha Ray, was appointed as the temporary guardian of a minor child shortly after the child's birth in 2015, with the father's consent. Over the next five years, the child's parents, Anthony Lowman and Kayla Morgan-Smart, contested the temporary guardianship. The magistrate court found no grounds to grant a permanent guardianship to the grandmother and aimed to reunify the child with the parents through a phased visitation plan. Despite this, the grandmother was held in contempt multiple times for failing to comply with court orders regarding visitation.The grandmother appealed the magistrate court's decisions to the district court. However, neither she nor her attorney, Wm. Breck Seiniger, filed the required opening briefs. The district court dismissed the appeal due to the failure to file timely briefs and found no good cause for the delay. The grandmother then filed a new notice of appeal from a subsequent contempt judgment, but again failed to file the necessary briefs on time, leading to the dismissal of the second appeal as well.The Supreme Court of Idaho reviewed the case and determined that Seiniger did not have the authority to represent the child, as he was never appointed by the magistrate court. The court also noted that the grandmother failed to challenge the district court's dismissal of her appeals in her briefing. Consequently, the Supreme Court affirmed the district court's decisions to dismiss the appeals and struck Seiniger's petition to intervene and notices of joinder. View "Ray v. Morgan-Smart" on Justia Law

A child was born to Anthony Lowman and Kayla Morgan-Smart in 2015. The child's paternal grandmother, Natasha Ray, was appointed as her temporary guardian shortly after birth. Ray was later allowed to intervene in the parents' divorce action to determine custody once the guardianship ended in August 2021. Before the guardianship ended, attorney Wm. Breck Seiniger, Jr. was asked by Ray to represent the child, which he accepted without court appointment. Seiniger filed a notice of appearance in the divorce action, which the parents objected to. The magistrate court ruled that Seiniger could not represent the child as there was no motion to appoint counsel, it was unnecessary at that stage, and a neutral attorney would be appointed if needed.The parents reached a custody agreement and filed a stipulation for joint custody. Despite the magistrate court's ruling, Seiniger objected to the proposed judgment on behalf of the child. The magistrate court overruled the objections and entered a judgment consistent with the parents' stipulation. Ray appealed the custody judgment to the district court, joined by Seiniger. The district court concluded that Seiniger had no authority to represent the child and dismissed the appeal, characterizing Seiniger as an "officious interloper." Ray's appeal was later dismissed for failure to provide timely briefing.The Supreme Court of Idaho reviewed the case and affirmed the district court's decision. The court held that the magistrate court acted within its discretion in rejecting Seiniger's representation of the child, as there was no motion to appoint counsel and it was unnecessary at that stage. The court also found that Seiniger's arguments were unpreserved and unsupported by sufficient authority. Consequently, the district court's order, including the decision to strike all pleadings filed by Seiniger, was affirmed. View "Lowman v. Morgan-Smart" on Justia Law

Dan Lee Gearhart and Kristin A. Marlar divorced in September 2018, with Gearhart ordered to pay monthly child support. Gearhart applied for Social Security Disability Insurance (SSDI) benefits for himself and his children, which were approved after the divorce, with payments retroactive to August 2018. The children’s benefits were paid to Marlar as their representative payee. Gearhart stopped making child support payments, believing the SSDI payments covered his obligation. In May 2022, Gearhart petitioned the magistrate court to credit the SSDI payments against his child support arrearage, effectively reducing it to $0.00. Marlar opposed this, arguing it constituted a retroactive modification of child support.The magistrate court credited the SSDI payments against Gearhart’s arrearage, eliminating his outstanding balance. Marlar appealed to the district court, which reversed the magistrate court’s decision, concluding that Idaho Code section 32-709 prohibited retroactive modification of child support. The district court remanded the case with instructions to deny the application of SSDI payments as a credit against Gearhart’s arrearage.The Supreme Court of Idaho reviewed the case and reversed the district court’s decision. The Supreme Court held that Idaho Code section 32-709 did not apply to Gearhart’s petition because he was not seeking a modification of his child support obligation but rather a credit for SSDI payments already made. The court concluded that section 32-709(2) did not limit the magistrate court’s discretion to credit SSDI benefits against the child support arrearage. The case was remanded to the district court with instructions to reinstate the magistrate court’s judgment crediting the SSDI payments against Gearhart’s arrearage. Neither party was awarded attorney fees on appeal. View "Marlar v. Gearhart" on Justia Law

Kadence Dawn Marble was a passenger in a vehicle stopped for speeding in Bonner County, Idaho. During the stop, the officer detected the smell of marijuana and found marijuana and drug paraphernalia in the vehicle. Marble admitted to knowing about the marijuana. She was charged with violating Idaho’s “frequenting” law, which makes it a misdemeanor to be present at a place where illegal controlled substances are held for distribution or use. Marble filed a motion to dismiss, arguing that a moving vehicle is not a “place” under the statute. The magistrate court agreed and dismissed the case.The State appealed to the District Court of the First Judicial District, which reversed the magistrate court’s decision. The district court concluded that Marble’s motion to dismiss was procedurally improper and that the question of whether a moving vehicle could be considered a “place” was a factual issue to be resolved at trial. Marble then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho reversed the district court’s decision, holding that the district court erred in failing to rule on the merits of the State’s appeal. The Supreme Court determined that whether a moving vehicle constitutes a “place” under Idaho Code section 37-2732(d) is a question of law, not fact. The Court held that a moving vehicle can be considered a “place” where illegal controlled substances are present. Additionally, the Court found that the statute is not unconstitutionally vague as applied to Marble’s conduct. The case was remanded to the district court with instructions to remand it to the magistrate court for a trial on the merits. View "State v. Marble" on Justia Law