Justia Idaho Supreme Court Opinion Summaries

Two individuals, who were in a long-term romantic relationship but never married, jointly purchased a piece of real property in Idaho. Both names were listed on the purchase and sale agreement and the warranty deed, but there was no specification of their respective ownership interests. After their relationship ended, one party attempted to transfer her interest in the property to a nonprofit and then reacquired it. The other party, who had paid all taxes, utilities, and expenses for the property, sought to quiet title in his name or, alternatively, to partition the property in kind, awarding him the entirety. The parties disputed whether ownership was equal or if one party had sole ownership.The District Court of the Seventh Judicial District, Bonneville County, initially denied both parties’ cross-motions for summary judgment, finding genuine disputes of material fact regarding ownership interests. After the Idaho Supreme Court issued Demoney-Hendrickson v. Larsen, which established a rebuttable presumption of equal ownership when a deed lists two names without specifying interests, the district court granted summary judgment to the defendant, concluding she had a 50% interest and ordering partition by sale. The court also determined the plaintiff had waived any claim for contribution because he had not pleaded it and awarded attorney fees to the defendant under Idaho Code section 12-121.The Supreme Court of the State of Idaho reviewed the case. It held that the district court erred in granting summary judgment to the defendant on the partition claim. The Supreme Court clarified that the plaintiff had provided sufficient evidence to establish a genuine dispute of material fact regarding the parties’ intent about their ownership shares, which should have precluded summary judgment. The court also clarified that a co-tenant listed on a deed can possess a 0% ownership interest, contrary to the district court’s conclusion. However, the Supreme Court affirmed the district court’s determination that the plaintiff had waived any claim for contribution. The Supreme Court reversed the grant of summary judgment on ownership, the denial of reconsideration, and the award of attorney fees, remanding for further proceedings. View "Bedell v. Parsons" on Justia Law

The case centers on a defendant who, while driving a semi-truck with a trailer, failed to stop at a stop sign and caused a fatal collision. He was initially charged with felony vehicular manslaughter but was acquitted of that charge by a jury and convicted instead of misdemeanor vehicular manslaughter. After the conviction, the defendant was granted a new trial due to an error in the jury instructions. Prior to the retrial, the presiding magistrate judge informed the parties off the record that he would not impose jail time if the defendant was convicted of the misdemeanor, consistent with typical sentencing practices for such offenses.Upon conviction at the second trial, the magistrate judge nonetheless sentenced the defendant to jail. The defendant filed a motion to reduce the sentence, arguing that the sentence was excessive and inconsistent with the judge’s prior assurances. The magistrate court reduced the jail time by one day but denied further relief. On appeal, the district court found that the magistrate’s assurances had tainted the judicial process and vacated the sentence, remanding the case to a different magistrate for resentencing. The new magistrate sentenced the defendant to 90 days in jail. The defendant again appealed, arguing that the new magistrate was bound by the prior assurance of no jail time, but the district court affirmed the sentence.The Supreme Court of the State of Idaho reviewed the case and held that the new magistrate was not bound by the prior judge’s assurances regarding sentencing. The Court found that the law of the case doctrine did not require the resentencing judge to follow the prior judge’s off-the-record statement and that the district court properly affirmed the new sentence. The district court’s decision was affirmed. View "State v. Salazar-Cabrera" on Justia Law

A group of residents and an association challenged actions taken by the Harris Ranch Community Infrastructure District No. 1 (CID) in Boise, Idaho. The dispute arose after the CID’s board adopted resolutions in 2021 authorizing payments to a developer for infrastructure projects—such as roadways, sidewalks, and stormwater facilities—and issued a general obligation bond to finance those payments. The residents objected to the projects, arguing they primarily benefited the developer, imposed higher property taxes on homeowners, and allegedly violated the Idaho Community Infrastructure District Act (CID Act) as well as state and federal constitutional provisions. Previously, the District Court of the Fourth Judicial District reviewed the matter after the residents filed a petition challenging the board’s decisions. The district court ruled in favor of the CID and the developer, concluding most of the residents’ claims were either time-barred under the CID Act’s statute of limitations or had been waived because they were not preserved before the CID board. The court also found that the remaining claims failed on their merits, holding that the challenged projects qualified as “community infrastructure,” the stormwater facilities satisfied ownership requirements, and the CID was not the alter ego of the City of Boise. On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court clarified that, given the lack of formal administrative proceedings under the CID Act, the preservation doctrine did not apply to bar the residents’ arguments. Nonetheless, the Supreme Court held that any challenge to the CID’s original formation and the 2010 bond election was time-barred. The court further held that the roadways and stormwater facilities qualified as community infrastructure, the CID’s actions did not violate constitutional requirements regarding taxation or lending of credit, and the CID was not the alter ego of the city. The Supreme Court awarded costs on appeal to the CID and the developer but denied attorney fees to all parties. View "Doyle v. The Harris Ranch Community Infrastructure District No. 1" on Justia Law

A healthcare provider and several of its employees became involved in a dispute after the Idaho Department of Health and Welfare took protective custody of a child suffering from severe malnutrition. Following the hospital’s treatment of the child, a relative of the child, using media platforms and political organizations, publicly accused the hospital and its staff of participating in a conspiracy to kidnap, traffic, and harm children. These accusations led to public protests, threats, and disruptions at the hospital. The healthcare provider and its employees then sued the relative, his associates, and affiliated entities, alleging defamation, invasion of privacy, intentional infliction of emotional distress, trespass, and civil conspiracy, among other claims. They sought compensatory and punitive damages, injunctive relief, and removal of false statements.During proceedings in the District Court of the Fourth Judicial District, the defendant repeatedly failed to comply with discovery orders, missed depositions, and did not attend court hearings, despite multiple warnings and opportunities to comply. The court imposed escalating sanctions, culminating in striking the defendant’s pleadings and entering default as to liability. The court held a jury trial solely on damages, at which the defendant did not appear in person despite being given the opportunity. The jury awarded $52.5 million in compensatory and punitive damages, and the court issued a permanent injunction preventing further defamatory statements or harassment.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in imposing sanctions, entering default, and excluding evidence not properly disclosed. The court found that the defendant’s due process rights were not violated given repeated, willful noncompliance with court orders. The Supreme Court affirmed the district court’s judgment, including the damages award and the injunction, and awarded attorney fees and costs on appeal to the respondents. View "St. Luke's Health System, LTD v. Rodriguez" on Justia Law

The dispute centers on two neighboring property owners at Priest Lake, Idaho, whose properties are subject to several easements, and who have a history of disagreements concerning the use of a shared beach, lake access, and parking. The parties previously reached a court-mediated settlement agreement addressing these issues, which included a provision for future mediation and arbitration of disputes. Disagreements soon arose, particularly over the construction of a patio by one owner, leading the parties to arbitration as provided by their agreement. The arbitrator, after considering substantial evidence and briefing, ruled in favor of one party on all contested issues, including the patio’s location and construction, the use of easements, and parking arrangements.Prior to this appeal, the District Court of the First Judicial District, Bonner County, reviewed a motion to vacate the arbitration award. The moving party argued that the arbitrator exceeded his authority and was biased, primarily because the award was unfavorable and allegedly altered the terms of the court-approved settlement agreement. After considering the arguments, the district court denied the motion, finding that the arbitrator had acted within the scope of his authority and that no evidence of bias was presented.Upon review, the Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that under Idaho’s Uniform Arbitration Act, judicial review of arbitration awards is extremely limited and does not allow for overturning an award simply due to alleged errors in law or fact, or because the outcome was unfavorable. The court found no evidence that the arbitrator exceeded his authority or acted with bias. Additionally, the court awarded attorney fees on appeal to the prevailing party under Idaho Code section 12-121, concluding the appeal was frivolous and without foundation. The district court’s denial of the motion to vacate was affirmed. View "Khalsa v. Ridnour" on Justia Law

Morgan Lohman purchased a 25.8-acre property, knowing that a homeowners’ association, Cave Bay Community Services, Inc., held a permanent easement on 7.31 acres and had an option agreement with the sellers, the Drehers, to purchase the easement land for one dollar once the Drehers’ loans were paid off. Despite concerns about the effect of this option on the value and use of his property, Lohman proceeded with the purchase. After the sale, the Drehers paid off their loans, and Cave Bay exercised its option to buy the easement property for one dollar, which Lohman refused to honor.Cave Bay filed suit against Lohman in the District Court of the First Judicial District of Idaho, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and seeking specific performance of the option agreement. Cave Bay moved for summary judgment only as to the specific performance “claim.” The district court granted summary judgment to Cave Bay on that basis, struck much of Lohman’s opposing declaration, and awarded Cave Bay attorney fees and costs. The court did not address the merits of the underlying breach of contract claim. After the parties dismissed the remaining claims, Lohman appealed.The Supreme Court of the State of Idaho reviewed the case and held that specific performance is a remedy, not a stand-alone cause of action. The court concluded that the district court erred by granting summary judgment on specific performance without first determining liability on the underlying breach of contract claim. The Supreme Court vacated the district court’s amended judgment, reversed the summary judgment ruling, and remanded the case for further proceedings. The court also vacated the award of attorney fees and costs, but awarded appellate costs to Lohman. No attorney fees were awarded on appeal as there was no prevailing party at this stage. View "Cave Bay Community Services v. Lohman" on Justia Law

A nonprofit organization, operating a camp for children with cancer, owned several buildings situated on land owned by a married couple. The couple, both involved in the nonprofit’s leadership, decided to sell the ranch property that included the camp’s buildings. During negotiations, the couple represented to the nonprofit’s board that appraisals did not specify values for the nonprofit's buildings and that the nonprofit’s share of sale proceeds should be calculated by square footage. Relying on these representations, the nonprofit accepted a portion of the sale proceeds. Subsequently, the nonprofit discovered that the appraisals had, in fact, assigned higher specific values to its buildings, resulting in a claim for damages against the couple for misrepresentation, breach of fiduciary duty, and unjust enrichment.The District Court of the Seventh Judicial District granted partial summary judgment to the couple on certain claims, but, after a bench trial, found in favor of the nonprofit on claims for constructive fraud, breach of fiduciary duty, and unjust enrichment. The court calculated the nonprofit’s damages but reduced the award by 50%, applying comparative negligence and the doctrine of avoidable consequences. The court denied attorney fees and prejudgment interest to both parties. Both sides appealed.The Supreme Court of the State of Idaho held that the doctrine of election of remedies did not bar the nonprofit’s appeal, as seeking satisfaction of a judgment is not inconsistent with seeking a greater award on appeal. The Court ruled that it was reversible error for the district court to reduce damages based on comparative negligence or a duty to mitigate, as those doctrines did not apply to the equitable and fiduciary claims at issue. The Court affirmed the district court’s rejection of the couple’s affirmative defenses of superseding intervening cause and unclean hands, as well as the finding that the wife breached her fiduciary duty. The denial of prejudgment interest and attorney fees was affirmed, but the nonprofit was awarded costs on appeal. The case was remanded for entry of judgment in the nonprofit’s favor for the full damages amount and reconsideration of prevailing party status. View "Camp Magical Moments, Cancer Camp for Kids, Inc. v. Walsh" on Justia Law

Several organizations and individuals petitioned to prevent the Idaho State Tax Commission from implementing a newly enacted parental choice tax credit. This tax credit, established in 2025, provides refundable credits to parents, guardians, and foster parents for certain private educational expenses, including private school tuition and related services, for dependent students not enrolled in public schools. The law caps total annual credits and includes prioritization based on income and previous participation. The petitioners, including advocacy groups, a school district, and parents, argued that the statute creates a separate, non-public education system funded by public resources, allegedly violating the Idaho Constitution’s mandate for a single, general, uniform, and thorough system of public schools. They also claimed the statute failed the “public purpose doctrine,” asserting it primarily benefits private rather than public interests.Before the Idaho Supreme Court, the petitioners sought a writ of prohibition, which would prevent the Tax Commission from carrying out the law. The respondents, including the State and the Idaho Legislature, contested the petitioners’ standing and the merits of the constitutional claims. The Supreme Court determined that the petitioners lacked traditional standing but, given the urgency and importance of the constitutional question and the absence of another suitable challenger, relaxed standing requirements to address the merits.The Supreme Court of Idaho denied the petition. It held that Article IX, section 1 of the Idaho Constitution does not restrict the legislature from enacting educational measures beyond the required public school system, so long as the public system remains intact and constitutionally sufficient. The Court also found that the tax credit serves a legitimate public purpose—supporting parental choice in education—even if private entities benefit. The petition was dismissed, and the Tax Commission was awarded attorney fees and costs. View "Committee to Protect and Preserve v. State" on Justia Law

Lewis Vanalen Borek was arrested for felony driving under the influence following a car accident in Star, Idaho. Officers at the scene administered a breathalyzer test, which returned a reading of .000, but Borek showed signs of impairment during field sobriety tests and admitted to taking anti-depressant medication. Subsequent blood tests revealed the presence of prescription drugs for mental health conditions. The State obtained records from the Idaho Prescription Monitoring Program (PMP), Ada County Jail, and Star Pharmacy, which included information about Borek’s prescriptions, medical history, and treatment.Borek initially moved to suppress all evidence from his arrest, arguing that officers lacked probable cause for a felony DUI, citing Idaho constitutional protections. The District Court denied his motion, but Borek appealed. The Idaho Court of Appeals reversed, agreeing that there was no probable cause for a felony DUI, and suppressed both the blood test results and statements made by Borek to medical staff. On remand, after further motions, the District Court allowed the State to obtain medical and prescription records from various sources. Borek filed a motion in limine to exclude these records, arguing they were privileged under Idaho Rule of Evidence 503. The District Court granted Borek’s motion, finding the records to be confidential communications protected by the psychotherapist-patient privilege.The Supreme Court of the State of Idaho reviewed the District Court’s order on permissive appeal. It held that the PMP and Star Pharmacy records did not constitute confidential communications under Rule 503(b)(2) and that Borek failed to meet his burden to prove that the Ada County Jail medical questionnaire was privileged. However, the State waived its challenge to exclusion of other jail records. The Supreme Court reversed the District Court’s order granting Borek’s motion in limine and remanded for further proceedings. View "State v. Borek" on Justia Law

A man was accused of surreptitiously recording his 13-year-old stepdaughter with his cellphone while she was undressing in the bathroom. His wife reported the incident to police, providing video evidence from a hidden camera that appeared to show him engaging in inappropriate conduct outside his stepdaughters’ bedrooms. Detectives confronted the man at his workplace, and after he indicated he wanted a lawyer, he handed over his cellphone when asked by police. The officers immediately informed him they were seizing the device but did not search it until obtaining a warrant the next day. Upon searching the phone, police found incriminating photos and videos, leading to a grand jury indictment on charges including video voyeurism and sexual exploitation of a child.The District Court of the Fourth Judicial District, Ada County, reviewed the defendant’s motion to suppress the cellphone and its contents, arguing the seizure was a Fourth Amendment violation due to the lack of a warrant or valid exception. At a suppression hearing, the court heard testimony from the detective about his concern that evidence could be quickly deleted if the phone was not seized immediately. The district court denied the motion to suppress, concluding that exigent circumstances justified the warrantless seizure because of the imminent risk that evidence would be destroyed.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s denial of the motion to suppress. The Idaho Supreme Court held that the warrantless seizure of the cellphone was justified under the Fourth Amendment’s exigent circumstances exception due to the risk of imminent destruction of evidence. The court clarified that this exception applied based on the totality of the circumstances and did not create a per se rule for all cellphone cases. The judgment of the district court was affirmed. The court also found that any issues regarding parole conditions were moot due to their removal from the amended judgment. View "State v. Smith" on Justia Law