Justia Idaho Supreme Court Opinion Summaries

Two unmarried individuals were in a long-term romantic relationship and jointly purchased real property in Idaho, with both names appearing on the purchase and sale agreement and the warranty deed. During their relationship, they lived together in California, and Bedell contributed to household expenses but not to rent or mortgage. After their relationship ended, Parsons attempted to quitclaim her interest in the Idaho property to a nonprofit, which then transferred it back to her. Bedell made the property his primary residence and filed suit seeking to quiet title in his name or, alternatively, to partition the property entirely to himself. Parsons counterclaimed, asserting she had a 50% interest and sought to quiet title in both names.The District Court of the Seventh Judicial District reviewed a series of summary judgment motions. It determined that Parsons had a 50% ownership interest in the property, relying on the presumption of equal shares when both parties’ names are on a deed without specified percentages, as set forth in Demoney-Hendrickson v. Larsen. The court found Bedell had not rebutted this presumption, ordered partition by sale, and awarded Parsons attorney fees. On reconsideration, the court maintained its conclusions, and later held that Bedell had waived any claim for contribution by not pleading it.The Supreme Court of the State of Idaho reviewed the case. It held that the district court erred by granting summary judgment to Parsons because genuine disputes of material fact existed regarding the parties’ intent about their respective ownership interests. The Supreme Court clarified that Idaho law does not preclude a co-tenant from having a 0% ownership interest, and the presumption of equal shares can be rebutted by evidence of the parties’ intent. The Supreme Court reversed the district court’s rulings on summary judgment, reconsideration, and attorney fees, but affirmed the finding that Bedell had waived any contribution claim. The case was remanded for further proceedings. View "Bedell v. Parsons" on Justia Law

A patient underwent a gallbladder removal surgery in Idaho Falls in 2019, performed by a board-certified general surgeon. The patient alleged that the procedure resulted in severe complications, including organ lacerations and emergency transport for further care. He claimed that the surgeon’s actions fell below the applicable community standard of care and filed a medical malpractice lawsuit. To support his claim, the patient sought to present testimony from an out-of-area, board-certified medical expert, who stated he had familiarized himself with the local standard of care by consulting a local surgeon practicing in the Idaho Falls/Pocatello area.The Seventh Judicial District Court of Idaho, Bonneville County, reviewed the affidavits submitted by the out-of-area expert. The court struck both the original and amended affidavits, finding that neither sufficiently demonstrated the expert’s foundation to testify regarding the community standard of care. The affidavits lacked specific information about the local surgeon’s familiarity with the Idaho Falls community standard and did not establish whether Idaho Falls and Pocatello were overlapping medical communities. As a result, the court granted summary judgment in favor of the defendant surgeon, concluding that the plaintiff had not presented admissible evidence on a necessary element of his claim. The court also awarded the defendant costs under Idaho Rule of Civil Procedure 54(d).The Supreme Court of the State of Idaho affirmed the district court’s rulings. It held that Idaho law requires out-of-area experts to demonstrate actual knowledge of the community standard of care, including showing how they became familiar with it, and that board-certified physicians are not automatically subject to a national standard. The court found the affidavits insufficient and upheld the grant of summary judgment and the award of costs to the defendant. The court also denied the plaintiff’s request for attorney fees on appeal. View "HEATH v. OLAVESON" on Justia Law

Wayne Morrison and his children contested the administration and distribution of two family trusts established by Wayne’s parents. The primary asset in both trusts was a fractional ownership of the Farnlun property. Wayne’s sister, Christina Thompson, acted as trustee for both trusts, and her daughter, Carolyn Hastings, was co-trustee of one. Wayne alleged breaches of trust and fiduciary duty, sought an accounting, and later added claims of fraud and partition by sale, naming Christina’s husband and children as additional parties. Christina, as trustee, sought to distribute trust assets in-kind to keep the Farnlun property in the family, while Wayne and his family opposed, favoring a sale and monetary distribution.The parties agreed to consolidate Wayne’s lawsuit and Christina’s petitions before the District Court of the Fifth Judicial District, Blaine County. The Morrisons moved to remove Christina and Carolyn as trustees, which the court denied. The court granted the Thompsons' motions for summary judgment, dismissing the partition claim, enforcing a no-contest clause that disinherited Wayne from one trust, approving in-kind distribution, and determining trust asset values and interests. The court also awarded attorney fees to the Thompsons against the Morrisons’ share of one trust.The Idaho Supreme Court reviewed the district court’s decisions. The Court affirmed all rulings: it found no abuse of discretion in the denial of trustee removal, held the Morrisons lacked standing for partition since they did not have a present possessory interest in the property, and upheld enforcement of the no-contest clause to disinherit Wayne. The Court found no error in the trust asset valuation and distribution and affirmed the attorney fee award and its assessment against the Morrisons’ share. The Supreme Court also awarded attorney fees and costs on appeal to the Thompsons, to be assessed against the Morrisons’ trust share. View "Morrison v. Thompson" on Justia Law

Three sisters and their parents owned and operated a family farm in Idaho through several business entities, including a limited partnership and various corporations. Over the years, the parents transferred ownership and control of these entities to one sister and her husband, who became general partners in the family limited partnership. The other two sisters, as limited partners, alleged that the general partners breached fiduciary duties by acquiring business assets at discounted prices and by purchasing family property for personal benefit, thereby depriving the partnership of business opportunities and diminishing their rights and expected inheritance.The District Court of the Third Judicial District, Gem County, reviewed the complaint, which asserted both direct and derivative claims. The court found that claims related to earlier transactions were barred by the statute of limitations, and that the plaintiffs’ allegations concerning the 2020 property purchase failed to demonstrate actual injury to either themselves or the partnership sufficient to establish standing. The court also determined that the plaintiffs had not met statutory pleading requirements for derivative actions, including adequately alleging demand futility, nor had they pled distinct personal injury for direct actions.The Supreme Court of the State of Idaho reviewed the district court’s dismissal de novo. It affirmed the dismissal, holding that the plaintiffs lacked standing for both direct and derivative claims because they failed to plead or prove injury independent of harm suffered by the partnership and did not satisfy statutory requirements for derivative actions. The Court also affirmed dismissal of the expulsion claim, finding insufficient allegations of wrongful conduct or distinct injury. Attorney fees and costs were awarded to the defendants for portions of the appeal deemed frivolous. View "Hyde v. Oxarango" on Justia Law

Law enforcement confronted a man after receiving reports from his wife that he had used his cellphone to secretly record his 13-year-old stepdaughter while she was undressing in the bathroom, and that a hidden camera had captured him engaging in sexual activity outside his stepdaughters’ bedroom doors. The wife provided police with video evidence, and prior incidents of similar behavior had also been reported. When detectives approached the man at his workplace and asked to see his phone, he handed it to them. Police immediately informed him that they were seizing the device. The next day, investigators obtained a warrant to search the contents of the phone, which revealed incriminating photos and videos. Based on this evidence, the man was indicted on multiple counts related to sexual exploitation and voyeurism of minors.The case proceeded in the District Court of the Fourth Judicial District, Ada County. The defendant moved to suppress the evidence from the cellphone, arguing its seizure violated his Fourth Amendment rights because it was taken without a warrant or a recognized exception. At a suppression hearing, the court heard testimony about the risk that evidence could be quickly deleted and the practicalities of obtaining a warrant. The district court denied the motion, finding the seizure justified by exigent circumstances due to the imminent risk of evidence being destroyed, and concluded the police acted reasonably in timing and duration. The defendant entered a conditional guilty plea, preserving his right to appeal.On appeal, the Supreme Court of the State of Idaho reviewed whether the warrantless seizure met constitutional standards. The court held that the seizure was justified by the exigency of potential destruction of evidence, that probable cause existed, and that the police acted in compliance with the Fourth Amendment. The judgment of the district court was affirmed. The issue of parole conditions was deemed moot because those conditions were removed in an amended judgment. View "State v. Smith" on Justia Law

After being involved in a rear-end collision, the defendant was arrested for felony driving under the influence in Idaho. Officers observed signs of impairment, but a breathalyzer test showed no alcohol. The defendant admitted to using anti-depressant medication. Subsequent blood tests revealed the presence of prescription drugs used for mental health treatment. As part of the investigation, the State obtained various records related to the defendant’s prescriptions and medical treatment from the Idaho Prescription Monitoring Program (PMP), Star Pharmacy, and Ada County Jail.Initially, the defendant moved to suppress evidence obtained from his arrest, arguing a lack of probable cause, and the Idaho Court of Appeals agreed, resulting in the suppression of certain statements and blood test results. On remand in the District Court for the Fourth Judicial District, the State sought the defendant’s medical and prescription records. Over the defendant’s objection, the court allowed the State to obtain these records. Before trial, the defendant filed a motion in limine to exclude the records, claiming they were protected by Idaho’s psychotherapist-patient privilege (Idaho Rule of Evidence 503). The district court granted the motion, finding the records were privileged and that the defendant had not waived this privilege by his statements to police.The Supreme Court of the State of Idaho reviewed whether the PMP, Star Pharmacy, and Ada County Jail records were privileged under Rule 503. The Court held that the PMP and Star Pharmacy records did not constitute “confidential communications” as defined by the rule, and that the defendant failed to prove the Ada County Jail medical questionnaire met the requirements for privilege. The Court reversed the district court’s order granting the defendant’s motion in limine and remanded for further proceedings. The Court affirmed only the part of the order concerning other jail records not challenged on appeal. View "State v. Borek" on Justia Law

The defendant was charged after driving a semi-truck through a stop sign, causing a fatal collision. Initially, he was tried for felony vehicular manslaughter but was acquitted of the felony and convicted of the lesser-included misdemeanor offense by a jury. After the first trial, the defendant challenged the jury instructions, leading the district court to grant a new trial on the misdemeanor charge. Before the retrial, the magistrate judge assured the parties at a pretrial conference that, if convicted, the defendant would not receive jail time, consistent with typical sentences for this offense. After the second trial, the defendant was again convicted, but the magistrate imposed a jail sentence, prompting the defendant to seek a reduction based on the earlier assurance.The magistrate court reduced the sentence by one day but otherwise denied the defendant’s motion. On appeal, the district court vacated the sentence, citing the impropriety of the magistrate’s assurance followed by the imposition of jail time, and remanded the case for resentencing by a different magistrate. At resentencing, the new magistrate imposed a jail sentence, declining to be bound by the earlier assurance. The defendant again appealed, arguing the new magistrate was required to honor the original judge’s promise of no jail time. The district court affirmed the new sentence.The Supreme Court of the State of Idaho reviewed whether the district court erred in affirming the magistrate court’s resentencing decision. The court held that the law of the case doctrine did not require the new magistrate to impose a sentence without jail time, as the district court’s remand order directed only that a different magistrate resentence the defendant, without mandating a particular sentence. The Supreme Court affirmed the district court’s decision, holding that the new magistrate properly exercised independent sentencing discretion within the applicable legal standards. View "State v. Salazar-Cabrera" on Justia Law

The appellant was convicted of first-degree murder and multiple related offenses following the 2002 death of his wife and a fire set in their home while children were present. Evidence at trial included proof of premeditation, the cause of death as asphyxiation and poisoning, arson, and circumstantial evidence linking the appellant to the crime. The defense argued the death was a suicide, but the jury found the appellant guilty and sentenced him to death, also imposing lengthy consecutive prison sentences for the other crimes. Over the next seventeen years, the appellant pursued a direct appeal and three petitions for post-conviction relief, all unsuccessful in overturning his conviction or sentence.Following the United States Supreme Court’s decision in Shinn v. Ramirez, the appellant filed a third successive post-conviction petition, arguing that changes in federal habeas law justified a new post-conviction proceeding. He advanced claims of ineffective assistance of counsel and sought to introduce new evidence and arguments regarding his innocence, equal protection, and separation of powers. The District Court of the Fourth Judicial District, Ada County, summarily dismissed the petition as untimely under Idaho Code section 19-2719, which imposes a strict 42-day deadline for post-conviction relief in capital cases, except in narrow circumstances not applicable here.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s dismissal. The Court held that there is no actual innocence exception to the 42-day statute of limitations for capital post-conviction relief under Idaho law, declined to overrule its prior precedent, and found no violation of equal protection or separation of powers. The holding clarifies that the statutory deadline is not subject to judicially-created exceptions apart from those provided by the legislature, and it does not violate constitutional guarantees. The judgment of dismissal was affirmed. View "Abdullah v. State" on Justia Law

The appellant pleaded guilty under an Alford plea to a charge of lewd and lascivious conduct with a minor and was sentenced to twenty years, with ten years fixed. He appealed his sentence as excessive, but the Idaho Court of Appeals upheld his conviction and sentence. Later, he filed a pro se petition for post-conviction relief, raising several “trial-error” claims—including alleged violations of his Fifth Amendment rights, issues with bail, breach of a prior plea agreement, insufficient evidence, and falsification of probable cause—as well as a claim for ineffective assistance of counsel on multiple grounds. Post-conviction counsel was appointed but did not amend the petition, and the State moved for summary dismissal, addressing only the ineffective assistance claim and not the trial-error claims.The District Court of the First Judicial District granted summary dismissal, finding only the ineffective assistance claim appropriate for post-conviction relief and concluding that claim was disproven or unsupported by admissible evidence. The court dismissed the trial-error claims on the ground that they could have been raised on direct appeal, without addressing them in the State’s motion or providing the appellant notice or an opportunity to respond. The appellant did not respond to the State’s motion but stipulated to decision on the written record. The Idaho Court of Appeals affirmed, concluding that the appellant had failed to preserve a lack-of-notice challenge because he did not move for reconsideration.The Supreme Court of the State of Idaho held that the district court erred by dismissing the trial-error claims sua sponte without giving the required twenty-day notice and opportunity to respond under Idaho Code section 19-4906(b). However, it affirmed dismissal of the ineffective assistance claim, finding the State’s motion provided adequate notice. The Supreme Court affirmed in part, reversed in part, and remanded for further proceedings on the trial-error claims. View "Best v. State" on Justia Law

A state trooper in Idaho observed two individuals near motorcycles without license plates in the parking lot of a hotel in a high-crime area. One motorcycle had been spray painted, which the trooper found suspicious. After running the vehicle identification number, he learned one motorcycle was stolen. The trooper tracked the individuals to a nearby gas station, ordered them to the ground, and placed both in handcuffs, later identifying the male as Benny Dean Campbell. The trooper discovered Campbell was on felony probation and, after contacting the Idaho Department of Correction, confirmed Campbell had signed a Fourth Amendment waiver, authorizing a search of his backpack. Heroin, methamphetamine, and paraphernalia were found in the backpack, leading to multiple charges against Campbell.The District Court of the Fourth Judicial District found that Campbell’s detention amounted to an unlawful de facto arrest because the State failed to show any officer safety concerns justifying handcuffing. However, the court admitted the evidence based on the attenuation doctrine, reasoning that the discovery of Campbell’s probation status and the subsequent probation officer’s authorization to search were intervening factors. Campbell entered a conditional guilty plea, reserving the right to appeal the suppression ruling.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s denial of Campbell’s suppression motion. The court agreed that Campbell’s detention became a de facto arrest without sufficient justification. However, it held that the evidence should not be suppressed under the inevitable discovery doctrine, finding it was inevitable that, absent the unlawful arrest, the trooper would have discovered Campbell’s probation status and the search would have lawfully occurred. The Supreme Court affirmed the district court’s order, albeit on a different theory, and upheld Campbell’s conviction. View "State v. Campbell" on Justia Law