Justia Idaho Supreme Court Opinion Summaries

During a traffic stop, police confiscated a pipe, a bong, and some marijuana possessed by defendant-appellant Richard Heath. Heath was charged with misdemeanor possession of marijuana and misdemeanor possession of drug paraphernalia. Heath moved to suppress the pipe and bong as evidence against him and the magistrate court granted the motion. Heath also moved for the return the pipe and the bong under Idaho Criminal Rule 41(f), but the magistrate court denied the motion after holding that the pipe and bong were contraband. Heath appealed the denial of his motion to the district court, which affirmed. Finding no reversible error, the Idaho Supreme Court also affirmed. View "Idaho v. Heath" on Justia Law

In 2004, a jury found Azad Haji Abdullah guilty of first-degree murder, first-degree arson, three counts of attempted first-degree murder, and felony injury to a child. He was sentenced to death for the murder. Abdullah filed a petition for post-conviction relief, which was dismissed by the district court in 2011. Abdullah then filed a consolidated appeal that included a direct appeal from his convictions and sentences and an appeal from the district court’s dismissal of his petition for post-conviction relief. The Idaho Supreme Court, in Idaho v. Abdullah, 348 P.3d 1 (2015), affirmed the convictions, sentences, and denial of post-conviction relief. In 2013—after the district court issued its order dismissing the petition for post-conviction relief, but prior to the Supreme Court’s issuance of Abdullah in 2015—Abdullah filed a successive petition for post-conviction relief. The Successive Petition was amended in 2016 and 2017. Abdullah also filed a pro se supplement to the successive petition that was incorporated with the successive petition. The successive petition and supplement included substantive claims, claims of ineffective assistance of trial counsel, and claims of ineffective assistance of appellate counsel. The district court determined that Abdullah was not entitled to post-conviction relief and summarily dismissed his successive petition and Supplement. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s dismissal. View "Abdullah v. Idaho" on Justia Law

The plaintiffs were indigent defendants represented in criminal actions by attorneys provided through Idaho’s public defense system. They alleged that numerous inadequacies in Idaho’s public defense system, as administered by the State and the Idaho Public Defense Commission (“PDC” or together “Respondents”), violated the rights of the named plaintiffs, as well as those of similarly situated criminal defendants across Idaho, under the Sixth and Fourteenth Amendments to the U.S. Constitution and Article I, Section 13 of the Idaho Constitution. In 2019, the district court denied cross motions for summary judgment, citing a lack of precedent as to the controlling legal standard to be applied, and requested this appeal. The Idaho Supreme Court granted the district court’s request for permissive appeal to determine the standard of review. The central issue presented for the Supreme Court's review centered on how to properly evaluate the deficiencies in Idaho’s public defense systems alleged by Appellants. In sum, Appellants insisted that a broader view was sufficient, while Respondents demanded the district court examine this issue closely. The Supreme Court held that both views were necessary: "a close up view, which allows for greater specificity, must be applied to the individual claims of at least one of the named plaintiffs whose allegations formed the basis of standing; however, a more distant view, which allows for greater overall perspective, is permissible for the examination of the systemic constitutional shortcomings alleged by Appellants." View "Tucker v. Idaho" on Justia Law

While responding to a call regarding an ongoing robbery at a mobile home park in Grangeville, Idaho, officers with the Grangeville Police Department interacted with defendant-appellant William Clark. Upon learning that Clark had an outstanding warrant for his arrest in Nez Perce County, Idaho, the officers attempted to arrest him. Clark fled, first entering a nearby home where the owner of the home implored him to leave. After exiting the first home, Clark entered the home next door, successfully evading the officers for approximately ten minutes. The officers eventually located Clark, hiding underneath a bed in the second home, where he was arrested. After a bench trial, the district court found Clark guilty on both counts of felony unlawful entry, concluding that the officers’ pursuit to execute the arrest warrant constituted “fresh pursuit” as defined in Idaho Code section 19-705. Clark appealed, arguing that pursuit to execute an outstanding warrant did not fall under either the common law or statutory definition of “fresh pursuit.” As a result, Clark argued the State failed to present sufficient evidence of the pursuit element for felony unlawful entry. Finding that "fresh pursuit," as defined in section 19-705 included pursuit to execute an arrest warrant, the Idaho Supreme Court affirmed Clark's conviction. View "Idaho v. Clark" on Justia Law

Defendant Melonie Smith appealed her conviction for first degree murder and destruction, alteration, or concealment of evidence. On appeal, Smith claimed the district court: (1) erred when it denied her motion to suppress; (2) abused its discretion when it admitted certain testimony over her objection; and (3) committed fundamental error by (a) admitting a video and (b) not striking the prosecutor’s comments in closing arguments. Smith further argued she was deprived of her right to a fair trial due to the accumulation of errors. Finding no reversible error, the Idaho Supreme Court affirmed her convictions. View "Idaho v. Smith" on Justia Law

Appellants were five individuals and one Idaho limited liability company (collectively, “Plaintiffs”) who owned real property in the City of Boise (“City”) and paid ad valorem taxes to Ada County, Idaho. Plaintiffs brought an action in district court challenging ordinances the City passed that allocate tax increment financing (“TIF”) revenues to Capital City Development Corporation (“CCDC”), the City’s urban renewal agency. Specifically, the ordinances approved the allocation of TIF revenues for CCDC’s use in the Shoreline District Urban Renewal Project Area and Gateway East Economic Development District Project Area. Because Plaintiffs’ alleged injuries were solely predicated upon their status as taxpayers, the district court dismissed their complaint for lack of standing. On appeal to the Idaho Supreme Court, Plaintiffs alleged they had standing under Koch v. Canyon County, 177 P.3d 372 (2008), in which the Supreme Court held that no particularized harm was necessary to establish taxpayer standing where a violation of article VIII, section 3 of the Idaho Constitution was alleged. Because the Supreme Court determined here that, as a matter of law, the ordinances Plaintiffs challenged did not violate article VIII, section 3, it affirmed the judgment of the district court. View "Hoffman v. City of Boise" on Justia Law

In this case, the Idaho Supreme Court was asked to revisit its decision in Idaho v. Clarke, 446 P.3d 451 (2019), and determine whether its holding was applicable in an administrative proceeding regarding the suspension of driving privileges based on an alleged case of driving under the influence (“DUI”). The Idaho Transportation Department (“ITD”) appealed a district court’s decision overturning its one-year suspension of Jasmine Reagan’s driving privileges. ITD based the administrative license suspension (“ALS”) on Reagan’s arrest for misdemeanor driving under the influence of alcohol and the results of subsequent testing of her blood alcohol content (“BAC”). The arresting officer, acting on a citizen’s report of a possible intoxicated driver, did not personally witness Reagan operating or in control of a vehicle. Reagan failed field sobriety tests administered at her home and, after being arrested, failed a breathalyzer test. Reagan received notice that her driver’s license was suspended for one year, which she appealed. An administrative hearing officer for ITD, relying on Idaho Code section 49-1405, upheld the license suspension. However, on appeal the district court overturned the suspension pursuant to Clarke, reasoning that because the misdemeanor DUI was completed outside the officer’s presence, the arrest required a warrant. On certiorari review, the issues presented were: (1) whether the breathalyzer test was administered pursuant to a lawful arrest; and (2) if the arrest was unlawful, whether test results obtained pursuant to an unlawful arrest are admissible in an ALS hearing before the ITD. The SupremeCourt concluded Idaho Code section 49-1405, as applied in this case, violated the Idaho Constitution. Accordingly, the Court affirmed the district court's decision to overturn ITD's suspension of Reagan's license. View "Reagan v. Idaho Transportation Department" on Justia Law

Citizens Against Linscott/Interstate Asphalt Plant (“CAL”) challenged a conditional use permit (“CUP”) issued by the Bonner County, Idaho Board of Commissioners (“the County”). The CUP was based on a recent amendment to Bonner County zoning ordinances (“the Amendment”) and authorized Interstate Concrete and Asphalt Company (“Interstate”) to operate an asphalt batch plant within Frank and Carol Linscott’s gravel mine in Sagle, Idaho. In its petition for judicial review by the Bonner County district court, CAL challenged both the validity of the Amendment and the County’s decision to issue the CUP. The district court determined that CAL had standing to file its petition for judicial review of the CUP and that CAL had timely filed its petition. However, the district court concluded that it could not declare the Amendment invalid in a proceeding for judicial review under Idaho Local Land Use Planning Act (“LLUPA”) and the Idaho Administrative Procedure Act (“IDAPA”). Accordingly, the district court upheld the County’s decision to grant the CUP, giving the County deference in applying its own land-use ordinances. During the pendency of this appeal, CAL filed an action for declaratory relief before another district court judge to have the Amendment declared void. In that proceeding, the County admitted that the Amendment had been adopted without proper public notice and stipulated to a judgment and order declaring the Amendment void. On appeal of the administrative decision to the Idaho Supreme Court, CAL argued, among other things, that the subsequent voiding of the Amendment also invalidated the CUP or that the CUP was not issued in conformity with Bonner County zoning laws. After review, the Supreme Court affirmed in part, and reversed in part. The Court found the CUP authorizing the relocation of the Interstate asphalt batch plant to the Linscotts’ gravel mine was invalid because it was based on a void amendment to Bonner County Code. Further, the County acted in a manner that was arbitrary and capricious in refusing to address the gravel pit’s compliance with the nonconforming use provisions of BCRC. View "Citizens Against Linscott v. Bonner County Board of Commissioners" on Justia Law

Greg and Cyndi Gomersall filed suit on behalf of their minor child, W.G.G., claiming he received negligent medical treatment at St. Luke’s Regional Medical Center (SLRMC) in Boise when he was injured in December 2010. W.G.G. was 6 years old at the time of the incident. The Gomersalls filed suit against SLRMC on January 25, 2019, more than eight years after W.G.G. was alleged to have been injured. SLRMC moved for summary judgment on the basis that the Gomersalls’ medical malpractice action was time-barred under Idaho Code sections 5-219(4) and 5-230. The district court granted SLRMC’s motion and dismissed the complaint with prejudice. The Gomersalls contended on appeal to the Idaho Supreme Court that the district court erred because Idaho Code section 5-230 was unconstitutional. Specifically, they argued that section 5-230 violated W.G.G.’s due process and equal protection rights by failing to toll the statute of limitations for medical malpractice claims until the age of majority. They also contended the district court erred when it held that the doctrine of equitable estoppel did not preclude SLRMC’s statute of limitations defense. Finding no reversible error, the Supreme Court affirmed the district court’s decision granting summary judgment in favor of SLRMC. View "Gomersall v. St. Luke's Regional Medical Center" on Justia Law

Fifteen-year-old Lucas Orozco was charged with robbery and burglary, both felonies, for allegedly robbing a convenience store. After a magistrate court determined there was probable cause to charge Orozco with the felonies, it waived juvenile jurisdiction and bound him over to district court as an adult pursuant to Idaho Code section 20-509. Orozco objected to this automatic waiver, filing a motion with the district court challenging the constitutionality of section 20-509. The district court denied the motion, relying on precedent from the Idaho Court of Appeals, which previously upheld the constitutionality of section 20-509. Orozco appealed, arguing that the automatic waiver denied him procedural due process protections afforded to him by the U.S. Constitution. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Orozco" on Justia Law