Justia Idaho Supreme Court Opinion Summaries

Riley Lodge appealed a no contact order entered against him as a result of his being convicted of two counts of sexual battery of a minor child sixteen or seventeen years of age. After Lodge pleaded guilty to these two counts, the district court entered a no contact order which prohibited Lodge from having contact with the named victims and “[a]ll minor children.” On appeal, Lodge contended the district court abused its discretion by failing to provide an exception to the no contact order for two minor children who were also his biological children, and who were conceived as a result of the underlying sexual batteries. Lodge argued the district court failed to exercise reason because there was no evidence that he posed a threat to his own children. The Idaho Supreme Court found no abuse of discretion and affirmed the district court and the no contact order. View "Idaho v. Lodge" on Justia Law

Martin Edmo Ish appealed his conviction and sentence for one count of voluntary manslaughter. The State charged Ish with second-degree murder in November 2015 for the June 2009 killing of Eugene Lorne Red Elk in Pocatello, Idaho. Ish and friends were barhopping when at some point, Ish had a confrontation with staff at the Bourbon Barrel. Ish and his friends went a few blocks away to Duffy's Tavern. The friends returned to the Bourbon Barrel, but Ish did not; Barrel staff called Duffy's to alert them of Ish's earlier confrontation. Red Elk was working at Duffy's as a bouncer. He asked Ish to leave, and Ish complied. Later that night, however, Red Elk was discovered in Duffy's parking lot "gurgling blood." He had suffered a brain injury from blunt force trauma to the head; despite being life-flighted to a medical center in Idaho Falls, Red Elk died three days later. TO police, Ish admitted that he “blasted” Red Elk and he “was pretty sure he killed him because he was laying [sic] there gurgling.” A trial was held in April 2017 after which the jury found Ish guilty of the lesser-included charge of voluntary manslaughter. Ish appealed, claiming the trial order erred in seating and instructing the jury, and in making certain evidentiary rulings. After review, the Idaho Supreme Court vacated the judgment of conviction and remand for a new trial. The Supreme Court determined the district court’s finding that the prosecution did not strike Juror 3 with discriminatory intent was clearly erroneous. The Court affirmed the trial court in all other respects. View "Idaho v. Ish" on Justia Law

Michael Hayes was convicted by jury of felony battery on a correctional officer. Hayes appealed his judgment of conviction on three grounds: (1) the district court erred by failing to issue subpoenas for two medical professionals; (2) the district court abused its discretion by allowing the State to inquire into prior instances of Hayes’ conduct towards correctional officers; and (3) the district court abused its discretion by denying Hayes’ motion for a new trial. The Court of Appeals reversed the district court’s order denying Hayes’ requests for subpoenas, and held that the district court abused its discretion by allowing the State to inquire into prior instances of Hayes’ conduct. Accordingly, the Court of Appeals vacated the district court’s judgment of conviction and remanded the case for a new trial. The Idaho Supreme Court granted the State’s petition for review, and finding the district court did not err in issuing its judgment, the Supreme Court reversed the appellate court and affirmed the trial court's judgment of conviction. View "Idaho v. Hayes" on Justia Law

Natalie Shubert sued her former public defender, Michael Lojek, former Ada County chief public defender Alan Trimming, and Ada County (collectively the “Ada County Defendants”). In 2008, Shubert was charged with two felonies and pleaded guilty to both charges. Her sentences were suspended in each case, and she was placed on probation. After a probation violation in 2011, the Ada County district court entered an order extending Shubert’s probation beyond the time period allowed by law. The mistake was not caught. After Shubert’s probation should have ended in both cases, she was charged and incarcerated for a subsequent probation violation in 2014. Thereafter, in 2016, Shubert was charged with a new probation violation. Shubert was assigned a new public defender, who discovered the error that unlawfully kept Shubert on probation. Shubert’s new public defender filed a motion to correct the illegal sentence, raising the error that had improperly extended her probation. The district court granted Shubert’s motion to correct the illegal sentence and released Shubert from custody. Shubert then sued the Ada County Defendants, alleging false imprisonment, intentional infliction of emotional distress, negligence per se, negligence, and state and federal constitutional violations. The district court dismissed all of Shubert’s claims except for negligence. In denying the Ada County Defendants’ motion for summary judgment, the district court held that public defenders were not entitled to common law quasi judicial immunity from civil malpractice liability, and two provisions of the Idaho Tort Claims Act (ITCA) did not exempt public defenders from civil malpractice liability. The Ada County Defendants petitioned the Idaho Supreme Court pursuant to Idaho Appellate Rule 12. Finding no reversible error in the district court's judgment, the Supreme Court affirmed the district court’s order granting summary judgment, and remanded for further proceedings. View "Shubert v. Ada County" on Justia Law

Employers Resource Management Company (“Employers”) returned to the Idaho Supreme Court in a second appeal against the Idaho Department of Commerce. In 2014, the Idaho Legislature passed the Idaho Reimbursement Incentive Act (“IRIA”). The Economic Advisory Council (“EAC”), a body created under IRIA to approve or deny tax credit applications, granted a $6.5 million tax credit to the web-based Illinois corporation Paylocity, a competitor to Employers Resource Management Company. Employers claimed Paylocity’s tax credit created an unfair economic advantage. Paylocity, however, had yet to receive the tax credit because it did not satisfy the conditions in the Tax Reimbursement Incentive agreement. Having established competitor standing in Employers Res. Mgmt. Co. v. Ronk, 405 P.3d 33 (2017), Employers argued the Idaho Reimbursement Incentive Act was unconstitutional under the separation of powers doctrine. The district court dismissed Employers’s case upon finding the Act constitutional. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "Employers Resource Mgmt Co v. Kealy" on Justia Law

Thomas Hooley appealed a district court’s decision to dismiss his pro se filing entitled “Motion For New Trial Based on Evidence withheld in violation of Brady with attached exhibits in support of motion.” In July 2014, a jury convicted Hooley of first-degree kidnapping and aiding and abetting aggravated battery. Hooley unsuccessfully appealed his conviction to the Court of Appeals. The Idaho Supreme Court denied his petition for review and issued a remittitur on December 18, 2015. In May 2018, Hooley lodged a pro se filing with the district court. Almost 200 pages in length, the first pages of the filing were a “sparse” legal template on which Hooley handwrote information. In the substantive portion of the motion, Hooley wrote that a “New Trial motion based on evidence withheld in violation of Brady cannot be denied on basis that new trial would not have produced different outcome and such violations not subject to harmless error analysis.” He also included statements of law and citations. The district court treated the filing as an untimely motion for a new trial based on newly discovered evidence under Idaho Criminal Rule 34. The district court denied the motion as untimely, reasoning that Hooley’s motion was filed outside of the 2-year time constraint on Rule 34 motions because his underlying judgment of conviction became final on December 18, 2015, when the remittitur was issued. Hooley appealed and argued that the district court should have construed his filing as a petition for post-conviction relief. The Court of Appeals affirmed. After granting Hooley’s timely petition for review, the Idaho Supreme Court concurred with the district court and affirmed its order. View "Idaho v. Hooley" on Justia Law

Dave Christensen was indicted by a grand jury on five counts of lewd conduct with two minors under sixteen. The State notified Christensen of its intent to introduce interviews of the two alleged victims at trial under Idaho Rules of Evidence (“I.R.E.”) 803(4) and 803(24). At a pretrial hearing, the district court ruled the interviews were admissible because the victims’ statements were made for purposes of medical diagnosis or treatment. The interviews were admitted at trial by stipulation. A jury found Christensen guilty on four of the five counts. Christensen appealed the district court’s admission of the interviews. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Christensen" on Justia Law

Jeffrey Marsalis appealed a district court’s decision summarily dismissing his petition for post-conviction relief from his 2009 rape conviction. Marsalis alleged that his trial counsel was ineffective for failing to: (1) challenge the testimony of the State’s expert witness regarding his and the victim’s blood alcohol levels; (2) present favorable eyewitness testimony at trial; and (3) properly advise him of his speedy trial rights under the Interstate Agreement on Detainers (IAD). After review, the Idaho Supreme Court reversed in part, and affirmed in part the district court's decision. The Court affirmed the district court’s summary dismissal of Marsalis’s claim that trial counsel was ineffective for failing to call an allegedly favorable eyewitness at trial. However, it reversed and remanded the case for an evidentiary hearing on Marsalis’s claim that trial counsel was ineffective for failing to challenge the underlying methodologies supporting the State’s expert witness’s testimony and for failing to present an expert witness to discuss the scientific basis behind Marsalis’s blackout defense. The Court also remanded the case back to the district court so it could provide Marsalis with twenty days’ notice to respond to the court’s grounds for dismissing Marsalis’s claim that trial counsel was ineffective for failing to inform him of his speedy trial rights under the IAD. View "Marsalis v. Idaho" on Justia Law

Glen Ward appealed an order and final judgment of the district court granting the State’s motion for summary dismissal and dismissing his petition for post-conviction relief. In 2014, Ward was convicted of sexual abuse of a minor under 16 years of age after he pleaded guilty to all elements of the crime except for the sexual intent element, to which he entered an Alford plea. He was sentenced to 18 years imprisonment with a 7-year fixed term. Ward asked for, and was granted, appointment of counsel to represent him in the post-conviction relief proceedings. After granting the motion, the district court appointed a conflict public defender to represent Ward in the action. Although he had secured new counsel, Ward subsequently filed numerous pro se documents. Ward argued the district court abused its discretion by denying his motion to proceed pro se as moot. Ward also argued the district court erred in denying his motion to proceed pro se because a post-conviction petitioner has a right to proceed pro se. After review, the Idaho Supreme Court vacated in part and affirmed. The Court held that the district court should have refused to entertain Ward’s independent filings in the first place; to the extent that the district court entertained the filings made by Ward as opposed to by his attorney, it was error to do so. However, having come to the conclusion that the district court erred, not by ruling incorrectly on Ward’s purported motion, but by ruling on it at all, the Supreme Court did not need to reverse the district court’s separate order and final judgment granting summary dismissal. "Because we hold that there was no motion properly before the district court to be ruled upon in the first place, the district court’s denial of the purported motion has no impact on the propriety of its final decision and judgment dismissing Ward’s post-conviction petition on the merits." View "Ward v. Idaho" on Justia Law

In 2011, a district court granted Aaron Roth a temporary furlough while he was in jail for a probation violation. Under the furlough order, Roth was released from custody. Roth failed to return. In 2017, six years after he absconded, Roth was arrested and later charged with escape, a felony under Idaho Code section 18-2505. A jury found Roth guilty of escape. Roth then moved the district court for a judgment of acquittal under Idaho Criminal Rule (“I.C.R.”) 29, or in the alternative, to dismiss pursuant to I.C.R. 48(a)(2). The district court granted the motion to dismiss under I.C.R. 48(a)(2). The State appealed the district court’s dismissal. After review, the Idaho Supreme Court concluded the district court abused its discretion by dismissing Roth's case. "This ruling extended the reach of due process too far. ... Due process is not a rigid standard and is satisfied when a defendant is provided notice and an opportunity to be heard. Roth had his opportunity to be heard and was sufficiently notified of the furlough order’s requirements to satisfy due process based on the district court explaining the details of the furlough order on the record at the arraignment hearing. The fact, as found by the district court, that Roth did not receive a written copy of the furlough order does not vitiate the notice that Roth had received in court from the judge." The Supreme Court reversed dismissal and remanded for further proceedings. View "Idaho v. Roth" on Justia Law