Justia Idaho Supreme Court Opinion Summaries

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

This case arose from an Idaho Industrial Commission determination denying an application for unemployment benefits. William Wittkopf appealed pro se the Commission’s determination that he was ineligible for unemployment benefits because he voluntarily quit his job without good cause and he willfully made a false statement or willfully failed to report a material fact in his unemployment application. On appeal, Wittkopf challenged the factual findings made by the Commission and argued it violated his right to due process by taking into consideration the fact that he voluntarily terminated his employment approximately two and a half years prior to applying for unemployment benefits. After review, the Idaho Supreme Court concluded: (1) Wittkopf failed to provide a cogent argument on appeal regarding whether his right to due process was violated; (2) the Commission’s determination that Wittkopf voluntarily terminated his employment at Stewart’s Firefighter without good cause and without exhausting all reasonable alternatives was supported by substantial and competent evidence; and (3) the Commission’s determination that Wittkopf willfully made a false statement or willfully failed to report a material fact in order to obtain benefits was supported by substantial and competent evidence. Accordingly, the Commission’s decision and order denying Wittkopf’s application for unemployment benefits was affirmed. View "Wittkopf v. Stewart's Firefighter Food Catering, Inc." on Justia Law

In this appeal, the Idaho Supreme Court was asked to clarify the meaning and extent of a defendant’s Sixth Amendment right to conflict-free counsel. Appellant Alfredo Alvarado argued his rights were violated because his public defender had previously represented a witness who was adverse to him on a felony charge. After disclosing the conflict, Alvarado’s attorney agreed that he and the public defender’s office would decline any future representation of the witness. However, Alvarado argued that counsel continued to have an actual conflict of interest because his ongoing ethical duties to the witness and former client prevented him from effectively cross- examining the witness. Alvarado contended this resulted in a structural defect in the trial, which necessitated overturning his convictions. In the alternative, Alvarado argued his unified aggregate sentence of twenty years to life for attempted strangulation and domestic abuse was excessive. After review, the Supreme Court determined Alvarado failed to show his counsel's representation constituted a fundamental error. He neither demonstrated an error affected the outcome of the trial, nor shown that a structural error denied him the right to counsel during a critical stage of the proceeding. Therefore, the Court ruled Alvarado was not deprived of his Sixth Amendment right to conflict-free counsel. The Court also held the district court did not abuse its discretion in sentencing Alvarado to a twenty-year to life aggregate sentence on his two felony convictions. View "Idaho v. Alvarado" on Justia Law

Defendant Max Gorringe appeaeled a district court’s order amending of a no contact order. A no contact order was originally entered against Gorringe after he was initially charged with attempted strangulation in 2011. Upon acceptance of Gorringe’s guilty plea to that charge in 2012, the district court rescinded the existing no contact order and in its place included no contact provisions in the Judgment and Commitment. In 2018, Gorringe was charged with a misdemeanor for allegedly violating the no contact provisions contained in the original Judgment and Commitment. Gorringe sought clarification of the existing provisions originally entered the judgment, then moved to modify the no contact provisions. The parties stipulated to an amendment of the order in exchange for the dismissal of Gorringe’s misdemeanor charge. Although the district court expressed reservations regarding its jurisdiction to amend the no contact provisions that had been incorporated into the prior Judgment and Commitment, the district court nonetheless amended the 2012 no contact order based on the parties’ stipulation and the State’s assurance that the victim did not object to the amendment. Gorringe appealed the district court’s order amending the no contact provisions, asserting that the no contact provisions included in the 2012 Judgment and Commitment were invalid. Gorringe also claimed the district court lacked subject matter jurisdiction to amend the order in 2018. The Idaho Supreme Court concluded the no contact provision in the district court's 2012 Judgment was unenforceable; the court lacked jurisdiction to amend the 2012 no contact order. The district court order amending the no contact order was thus reversed, and the provisions in the 2012 sentencing order were void. View "Idaho v. Gorringe" on Justia Law

The State charged Carli Campbell as an accessory to a felony under Idaho Code section 18-205(1) for withholding or concealing information from police officers about an aggravated battery and burglary that occurred in her home in December 2017. After the evidentiary phase of the trial was completed, Campbell requested the district court instruct the jury that the State was required to prove that the alleged assailant, Michael Cross, committed the aggravated battery or burglary beyond a reasonable doubt. The State opposed this request and the district court agreed, concluding that while the State was required to prove Campbell had knowledge of the conduct that constituted an aggravated battery or a burglary, it was not was required to prove Cross committed the aggravated battery or burglary beyond a reasonable doubt. At the conclusion of the trial, the jury found Campbell guilty. Campbell now appeals her conviction to this Court. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed. View "Idaho v. Campbell" on Justia Law

In 1985, Gerald Pizzuto Jr. murdered Berta and Delbert Herndon. Pizzuto was convicted of two counts of murder in the first degree, two counts of felony murder, one count of robbery, and one count of grand theft. He was sentenced to death for the murders. Between 1986 and 2003, Pizzuto filed five petitions for post-conviction relief. His fifth petition for post-conviction relief was predicated on the holding in Atkins v. Virginia, 536 U.S. 304 (2002), in which the U.S. Supreme Court held that the execution of an intellectually disabled person constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. In his fifth petition, Pizzuto asserted that his death sentence should be “reversed and vacated” because he was intellectually disabled. The district court summarily dismissed Pizzuto’s petition. The Idaho Supreme Court held that the district court did not err when it dismissed Pizzuto’s fifth petition for post-conviction relief on the basis that Pizzuto had failed to raise a genuine issue of material fact supporting his claim that he was intellectually disabled at the time of the murders and prior to his eighteenth birthday. Pizzuto pursued this same claim in a federal habeas corpus action. In 2016, the U.S. District Court for the District of Idaho denied Pizzuto’s successive petition for writ of habeas corpus after holding a four-day evidentiary hearing in 2010. Although it affirmed the federal district court’s decision denying Pizzuto’s successive petition for writ of habeas corpus, the Ninth Circuit stated in dicta that its decision does not preclude Idaho courts from reconsidering whether Pizzuto was intellectually disabled at the time of the murders. Based on this dicta, Pizzuto filed a motion with the district court to alter or amend the judgment dismissing his fifth petition for post-conviction relief in accordance with Idaho Rule of Civil Procedure 60(b)(6). The district court denied Pizzuto’s Motion in early 2020. Because the district court did not abuse its discretion in denying Pizzuto’s Motion, the Idaho Supreme Court affirmed the district court’s decision. View "Pizzuto v. Idaho" on Justia Law