Justia Idaho Supreme Court Opinion Summaries

TCR, LLC, a Wyoming limited liability corporation, filed a lawsuit against Teton County, Idaho, after the County refused to record a Condominium Plat for property within a planned unit development (PUD) owned by TCR. TCR sought declaratory and injunctive relief, claiming the lot had already been approved for condominium development, and also alleged breach of a 1996 settlement agreement between the County and TCR’s predecessor. The district court granted TCR’s motion for summary judgment on the declaratory and injunctive relief claim, ordering the County to record the Condominium Plat, but granted the County’s motion for summary judgment on the breach of contract claim.The district court found that the County had previously approved amendments to the PUD Plat in 2018 and 2019, allowing TCR to build sixteen standalone condominiums on Lot 12B. The County’s refusal to record the Condominium Plat was based on an alleged site plan from 1995, which the district court found inadmissible. The district court concluded that the County had no legal basis to refuse the recording and enjoined the County from preventing TCR’s attempts to record the Plat.The Supreme Court of Idaho affirmed the district court’s decision to grant TCR’s claim for declaratory and injunctive relief, holding that the County had no valid reason to refuse the recording. However, the Supreme Court reversed the district court’s grant of summary judgment to the County on the breach of contract claim, finding that there were genuine issues of material fact regarding whether the County breached the 1996 Settlement Agreement. The case was remanded for further proceedings on this issue.The Supreme Court also found that the district court erred in denying TCR’s second motion to enforce, which sought to compel the County to issue building permits after the Condominium Plat was recorded. The Court awarded TCR its attorney fees and costs on appeal, concluding that the County acted without a reasonable basis in fact or law. View "TCR, LLC v. Teton County" on Justia Law

Robert Kenneth Wilde was charged with two felonies, including trafficking in heroin, and one misdemeanor possession of a controlled substance. One felony charge was dismissed, and Wilde pleaded guilty to trafficking in heroin, with the misdemeanor charge dismissed as part of a plea agreement. The plea agreement included a provision for Wilde to pay drug restitution for investigation costs. Wilde was sentenced to a mandatory minimum of ten years in prison, followed by twenty years indeterminate, and ordered to pay a $15,000 fine and $291 in restitution to the Idaho State Police. The State sought additional restitution for investigative costs, which Wilde contested, citing his lengthy sentence and diminished earning potential.The district court ordered Wilde to pay an additional $2,806.40 in restitution, considering his foreseeable ability to repay. Wilde appealed, and the Court of Appeals held that he waived his right to appeal the restitution order based on his plea agreement. The Court of Appeals also addressed the merits, concluding that Wilde failed to show error in the district court's decision.The Supreme Court of Idaho reviewed the case and disagreed with the Court of Appeals' decision to raise the issue of appellate waiver sua sponte, as the State had not raised it. The Supreme Court found that Wilde's plea agreement did not contain an appellate waiver regarding restitution under Idaho Code section 37-2732(k). On the merits, the Supreme Court held that the district court did not abuse its discretion in awarding additional restitution, as it adequately considered Wilde's foreseeable ability to repay, supported by substantial evidence. The Supreme Court affirmed the district court's restitution order. View "State v. Wilde" on Justia Law

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt in early 2024 due to the inability to establish reliable intravenous access. Following this, Creech filed a petition for post-conviction relief, arguing that any further attempt to execute him would violate his constitutional rights under the Fifth Amendment’s Double Jeopardy Clause and the Eighth Amendment’s prohibition against cruel and unusual punishment.The District Court of the Fourth Judicial District of Idaho dismissed Creech’s petition, construing his Eighth Amendment argument as a challenge to the method of execution, which it determined could not be litigated in a post-conviction action. The court suggested that Creech could pursue his Eighth Amendment challenge through other legal avenues, such as a 42 U.S.C. § 1983 action. The court also addressed the merits, finding that a second execution attempt did not violate the Fifth Amendment as it did not impose more punishment than authorized, nor did it violate the Eighth Amendment as the failed attempt did not involve intentional or malicious infliction of unnecessary pain.The Supreme Court of Idaho affirmed the district court’s dismissal. It held that Creech’s claims were properly raised under Idaho Code section 19-2719 but found no genuine issue of material fact warranting an evidentiary hearing. The court determined that the failed execution did not constitute cruel and unusual punishment under the Eighth Amendment, as the psychological strain and pain experienced were inherent in any execution method. Additionally, the court ruled that a second execution attempt did not violate the Double Jeopardy Clause, as the initial attempt did not complete the punishment authorized by the legislature. Creech’s state constitutional claims were not considered as they were not adequately preserved for appeal. View "Creech v. State" on Justia Law

Adrian Renee Soliz was found unconscious behind the wheel of his vehicle, which was impeding traffic. Concerned, a passerby called 9-1-1, and emergency responders arrived at the scene. They discovered drug paraphernalia on Soliz's lap while providing medical assistance for what was later confirmed to be a drug overdose. Soliz was subsequently charged with possession of a controlled substance, possession of drug paraphernalia, and other related offenses.Soliz filed a motion to dismiss the charges, arguing that under Idaho’s overdose immunity statute (Idaho Code section 37-2739C(2)), he should be immune from prosecution because the evidence was obtained as a result of his medical emergency. The State opposed the motion, contending that the evidence was discovered during a traffic investigation, not solely due to the medical emergency. The district court denied Soliz’s motion, concluding that the evidence was not obtained solely as a result of the medical emergency.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The Court held that the phrase “as a result of” in the overdose immunity statute means that the drug-related medical emergency must be the sole cause of the discovery of evidence. Since the evidence was discovered during both a traffic investigation and a medical emergency response, the statute did not apply. Therefore, Soliz was not entitled to immunity, and the district court’s denial of his motion to dismiss was upheld. View "State v. Soliz" on Justia Law

This case involves the reformation of a trust to remove male beneficiary restrictions and replace them with gender-neutral language to benefit successive generations of the Terteling family. Joseph L. Terteling, his former wife Carolyn E. Terteling, and their three granddaughters filed a petition to reform Terteling Trust No. 6 to reflect the alleged original intentions of the trustors to benefit Joseph’s successive generations, regardless of gender. Thomas J. Terteling, a contingent beneficiary, objected, arguing that the petitioners could not demonstrate by clear and convincing evidence that a mistake was made in the drafting of the Trust or that it was the intention of all the trustors to benefit successive generations regardless of gender.The magistrate court granted the petition, concluding that the stipulated facts demonstrated by clear and convincing evidence that a drafting error had occurred in restricting the class of beneficiaries to male children only. The court found that the trustors intended to benefit all the children and descendants of Joseph, regardless of gender. Thomas J. appealed to the district court, which affirmed the magistrate court’s decision.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The Court held that substantial and competent evidence supported the magistrate court’s findings that a mistake occurred in the drafting of the Trust and that the trustors intended to benefit a gender-neutral class of heirs. The evidence included declarations from Joseph and Carolyn, a 1978 affidavit signed by all the trustors, and TEDRA agreements from 2013 and 2021. The Court concluded that the male-only beneficiary restriction was a mistake and that the original intent of the trustors was to benefit successive generations of the family, regardless of gender. View "Terteling v. Terteling" on Justia Law

In 2018, Dustin Clover sustained injuries while removing irrigation drip tape from a seed field while working for Crookham Company. Clover filed a complaint against Crookham, alleging that his injuries fell within an exception to the exclusive remedy rule under Idaho’s 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 this claim. The district court agreed and granted summary judgment in favor of Crookham. Clover’s motion for reconsideration was also denied, leading him to appeal.The District Court of the Third Judicial District of Idaho initially reviewed the case. The court found that Clover’s injuries occurred during the course and scope of his employment and were covered by worker’s compensation. It concluded that Clover did not present sufficient evidence to show that Crookham’s actions met the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The court granted summary judgment to Crookham and denied Clover’s motion for reconsideration, which included new evidence and arguments that were deemed untimely and insufficient to alter the court’s original decision.The Supreme Court of the State of Idaho reviewed the case on appeal. The court affirmed the district court’s decision, holding that Clover failed to demonstrate that Crookham engaged in conduct knowing that employee injury would result. The court found no evidence that Crookham consciously disregarded knowledge of a significant risk posed by the drip tape lifter. Additionally, the court upheld the district court’s exclusion of evidence related to subsequent remedial measures and denied Clover’s motion for reconsideration, concluding that the new evidence presented did not raise a genuine issue of material fact. The Supreme Court awarded costs to Crookham as the prevailing party. View "Clover v. Crookham Company" on Justia Law

This case involves child custody proceedings between Isaac William Hess and Lisa Ann Hess, who have two minor children registered as members of the Cherokee Nation. Isaac alleged that Lisa abused the children by spanking them with a PVC pipe and claimed she was a negligent mother. During the proceedings, Isaac's father was briefly granted emergency guardianship by the District Court of the Cherokee Nation, but the case was dismissed due to jurisdictional issues. The Idaho magistrate court awarded Lisa sole physical custody and joint legal custody with final decision-making authority, and ordered Isaac to pay child support backdated to January 1, 2021.Isaac appealed to the district court, arguing that the magistrate court erred by not consulting with the Cherokee Nation court regarding jurisdiction, failing to refer his child abuse allegations to the Idaho Department of Health and Welfare (DHW), focusing on only one statutory factor in awarding custody, effectively granting Lisa sole legal custody without proper findings, and backdating the child support award. The district court affirmed the magistrate court's decisions on jurisdiction, the child abuse referral, and physical custody, but Isaac appealed further.The Supreme Court of Idaho affirmed the district court's decisions on jurisdiction, the child abuse referral, and physical custody. The court held that the magistrate court correctly determined it had jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) and that Isaac's allegations did not constitute child abuse under Idaho law. However, the court reversed the district court's affirmation of the magistrate court's decisions on legal custody and backdated child support. The magistrate court's legal custody decision was found to be internally contradictory, and its decision to backdate child support deviated from the Idaho Child Support Guidelines without explanation. The case was remanded for further proceedings on these issues. The court also awarded Lisa partial attorney fees for responding to Isaac's jurisdictional argument. View "Hess v. Hess" on Justia Law

The case involves the Schrivers, who sought damages after their cat, Gypsy, died following a veterinary procedure and was subjected to an unauthorized necropsy by Dr. Raptosh and Lakeshore Animal Hospital. The Schrivers claimed non-economic damages for emotional distress and loss of companionship, arguing that the emotional bond between pet and owner should be compensable. They also sought economic damages based on the pet's value to them.The District Court of the Third Judicial District of Idaho granted summary judgment in favor of Dr. Raptosh and Lakeshore on several claims, including negligent infliction of emotional distress, intentional infliction of emotional distress, and lack of informed consent. The court denied the Schrivers' claim for emotional distress damages related to trespass to chattels/conversion but allowed the "value to owner" measure of economic damages for the loss of Gypsy.The Supreme Court of Idaho affirmed the district court's decision in part and reversed in part. The court upheld the denial of emotional distress damages for trespass to chattels/conversion, agreeing that such damages are limited to independent torts of negligent or intentional infliction of emotional distress. The court also affirmed the summary judgment on the negligent infliction of emotional distress claim, holding that veterinarians do not have a duty to prevent emotional harm to pet owners. However, the court reversed the summary judgment on the intentional infliction of emotional distress claim related to the unauthorized necropsy, finding that a jury should decide if the conduct was extreme and outrageous. The court affirmed the use of the "value to owner" measure of damages, excluding sentimental value.The case was remanded for further proceedings on the intentional infliction of emotional distress claim. The Schrivers were awarded costs on appeal, but attorney fees were not granted to Dr. Raptosh and Lakeshore, as the primary issue of liability remains unresolved. View "Schriver v. Raptosh" on Justia Law

Catherine Sullivan, trustee of the Catherine Sullivan Family Trust of 2000, owns residential property adjacent to Megan Gruver's equestrian facility, Silver Bell Ranch, in Blaine County, Idaho. Gruver was issued a conditional use permit (CUP) in 2019 to operate the facility, which Sullivan did not appeal. In 2021, Gruver sought modifications to the CUP to hold three events per year, board additional horses, and hire more staff. Sullivan objected, citing concerns about noise, traffic, and property devaluation, but the Blaine County Board of Commissioners approved the modified CUP with conditions.Sullivan appealed the Board's decision to the district court, arguing that the Board erred in categorizing Silver Bell Ranch as an "Outdoor Recreational Facility" rather than an "Agricultural Business" and that the modifications would prejudice her substantial rights. The district court affirmed the Board's decision, finding that Sullivan failed to show how the modifications prejudiced her substantial rights and that her arguments regarding the categorization of the facility were time-barred because she did not appeal the 2019 CUP.The Idaho Supreme Court reviewed the case and affirmed the district court's decision. The Court held that Sullivan's arguments regarding the categorization of Silver Bell Ranch were time-barred and that she failed to establish prejudice to her substantial rights under Idaho Code section 67-5279(4). The Court also found that the district court acted within its discretion in excluding Sullivan's arguments related to prejudice that were raised for the first time in her reply brief. Blaine County was awarded attorney fees on appeal under Idaho Code section 12-117(1), while Gruver was not entitled to attorney fees as she was not an adverse party to Blaine County. Both Blaine County and Gruver were awarded costs on appeal. View "Sullivan v. Blaine County" on Justia Law

Jacob Wilde and Mickayla Taggart, formerly married, are parents to a minor child, E.W. Following their divorce in 2018, Wilde was ordered to pay $143.07 per month in child support. Wilde later filed petitions to modify the custody arrangement and child support, citing Taggart's alleged incapacity and unemployment. Taggart responded, explaining her inability to work due to an autoimmune disease and requested child support modification based on the Idaho Child Support Guidelines.The magistrate court found that Taggart's income had been minimal since the petition was filed and imputed her income at minimum wage. Wilde's income was determined to be $58,240 annually. The court retroactively modified child support to $420.34 per month starting August 2019, creating an arrearage for Wilde. Wilde's motion to reconsider was denied, and the magistrate court reaffirmed its decision, adjusting the child support amount to $485.34 from June 2021.Wilde appealed to the district court, which affirmed the magistrate court's decision. The district court found that the magistrate court had substantial evidence to support its findings and did not abuse its discretion in making the child support modification retroactive.The Idaho Supreme Court reviewed the case and upheld the district court's decision. The court found that the magistrate court acted within its discretion, supported by substantial evidence of the parties' changed incomes. The court noted that Wilde had been aware of the potential for retroactive modification and had not disputed the child support calculations. The Supreme Court awarded attorney fees and costs to Taggart, deeming Wilde's appeal frivolous and without foundation. View "Wilde v. Taggart" on Justia Law