Justia Idaho Supreme Court Opinion Summaries

Petitioner-appellant John Bradbury was resident of the City of Lewiston, Idaho and was an elected member of its city council. While serving in that capacity, he filed a petition alleging nine causes of action concerning various City funds and services, including those related to water, sanitation, wastewater, city streets, the library, and the municipally-owned Bryden Canyon Golf Course. Bradbury contended the City had been collecting excessive utility fees and improperly spending municipal funds. Bradbury sought declaratory and equitable relief. He appealed when the district court dismissed most of his claims at summary judgment, and raised additional errors for appellate review. The Idaho Supreme Court determined only that the district court erred in determining that the Idaho Tort Claims Act (“ITCA”) precluded recovery on a constitutional claim seeking equitable relief. The Court determined a remand was unnecessary where Bradbury conceded he was seeking no such remedy for himself. The Court affirmed the district court in all other respects. View "Bradbury v. City of Lewiston" on Justia Law

Brandon Bahr appealed a district court’s summary dismissal of his untimely petition for post-conviction relief. Bahr filed his untimely petition roughly two years after the one-year statute of limitations had expired. The State responded with a motion seeking summary dismissal. Bahr opposed dismissal, arguing the limitations period should have been equitably tolled based on his alleged lack of access to the Idaho courts while transferred to, and incarcerated in, Texas prison facilities. The district court granted the State’s motion for summary dismissal. Bahr argued on appeal to the Idaho Supreme Court that the district court erred by denying him equitable tolling, and by declining to hold an evidentiary hearing concerning whether Bahr lacked access to the Idaho courts while incarcerated in Texas. The Supreme Court affirmed: "Even if Bahr was denied access to the Idaho courts while in Texas, a fact which we have not determined, he is not entitled to equitable tolling because he failed to allege any diligent efforts to pursue his rights while in Texas." View "Bahr v. Idaho" on Justia Law

This case stemmed from a 2019 lease by Respondents the City of Sandpoint (“the City”) to The Festival at Sandpoint (“The Festival”), a nonprofit corporation, to operate a multi-day music concert series in War Memorial Field Park. The Festival had a long-standing policy of prohibiting festival patrons from bringing weapons, including firearms, into the event. On August 9, 2019, Scott Herndon and Jeff Avery purchased tickets to the festival and attempted to enter. Avery openly carried a firearm and Herndon possessed a firearm either on his person or in a bag (the record was unclear on this point). Security personnel for the event denied entry to both. After discussions with a City police officer and the City’s attorney, who was coincidentally attending the same event in his private capacity, Herndon and Avery eventually left the music festival and received a refund for their tickets. Appellants Herndon, Avery, the Idaho Second Amendment Alliance, Inc., and the Second Amendment Foundation, Inc. subsequently sued the City and The Festival, asserting several claims, including seeking injunctive relief prohibiting the Respondents from violating the Idaho and United States Constitutions, particularly the Second Amendment and the Idaho Constitution’s provision securing the right to keep and bear arms in public for all lawful purposes. The district court ultimately granted the Respondents’ motions for summary judgment, awarded both the City and The Festival attorney fees and costs, and dismissed all the Appellants’ claims with prejudice. The issue raised on appeal was whether a private party who leased public property from a municipality may govern those who come and go from the property during the lease. The Idaho Supreme Court responded in the affirmative, and affirmed the district court's judgment. View "Herndon v. City of Sandpoint" on Justia Law

Petitioner Todd Wood appealed after his driving privileges were suspended following breath alcohol testing (BAC) by the Idaho State Policy. After a lawful traffic stop, Wood submitted to BAC testing. His results were 0.178 and 0.175, both in excess of Idaho’s legal limit of 0.08. However, during the fifteen-minute pretest observation period, the deputy sheriff admittedly did not observe Wood for roughly three minutes to ensure mouth alcohol was not present by way of burp, external contaminant, or otherwise prior to evidentiary testing. Wood challenged his suspension and argued that his BAC results were inadmissible because they had not been obtained in compliance with the required fifteen-minute pretest observation procedure. The ALS hearing officer disagreed, reasoning that ISP had promulgated rules making the pretest observation period only discretionary; thus, Wood’s BAC test results were not based on unlawful procedure. Wood petitioned for judicial review and argued the BAC rules allowing for a discretionary observation period are violative of “due process” and “fundamental fairness.” Wood further argued that the automatic admission of BAC results in his ALS hearing, pursuant to section 18-8004(4), unconstitutionally usurped the judicial branch’s power over the admission of evidence. The district court rejected Wood’s arguments and upheld his administrative license suspension. Wood appealed to the Idaho Supreme Court on the same grounds, which likewise upheld the suspension. View "Wood v. ITD" on Justia Law

Sean Anderson appealed his conviction and sentence for aggravated assault on a police officer. Anderson argued on appeal: (1) the district court erred by instructing the jury on a different theory of assault than what was alleged in the charging Information; (2) the district court erred by refusing to give his proposed jury instruction on the misdemeanor offense of discharge of a firearm aimed at another; and (3) the district court imposed an excessive sentence. The Idaho Supreme Court affirmed Anderson’s judgment of conviction, finding that the district court did not abuse its sentencing discretion. View "Idaho v. Anderson" on Justia Law

Defendant Stacy Ingraham appealed her convictions and sentences for possession of methamphetamine, possession of marijuana, possession of drug paraphernalia, destruction of evidence, and grand theft by possession of stolen property. She argued she was denied her right to a public trial under both the Idaho and U.S. constitutions, and that the district court erred by publishing a video exhibit to the jury after it began deliberations. Additionally, she contended the district court erred in allowing the jury to consider a prior felony conviction for purposes of a persistent violator enhancement where that conviction had previously been “deemed” a misdemeanor pursuant to Idaho Code section 19-2604. After review, the Idaho Supreme Court affirmed defendant's convictions, but vacated the sentence and remanded for resentencing. View "Idaho v. Ingraham" on Justia Law

A coalition of media companies petitioned the Idaho Supreme Court for a writ of mandamus or a writ of prohibition to vacate a nondissemination order issued by the magistrate court in the pending criminal action of State of Idaho v. Bryan C. Kohberger. The Supreme Court expedited the case and ordered briefing from the parties. The Court also granted motions to intervene filed by the two parties to this case, the State of Idaho, Latah County Prosecutor (“the State”) and the defendant, Bryan Kohberger, who were also permitted to file briefs. After review of the briefs submitted, the Supreme Court dispensed with oral argument was unnecessary to resolve this case. The underlying case involved the 2022 murder of four University of Idaho students, for which Kohberger was arrested and charged with committing. The case drew widespread publicity. Recognizing the high-profile nature of the case and the extensive coverage it has received, along with the need to minimize possible pretrial prejudice, Kohberger’s attorneys and the attorneys for the State stipulated to the nondissemination order. Shortly after the order was entered, the medial companies challenged the constitutionality of the mondissemination order and sought extraordinary relief to protect free speech rights and the media’s ability to cover the case under the U.S. and Idaho Constitutions. The Supreme Court ultimately concluded that neither a writ of mandamus nor a writ of prohibition were appropriate remedies at this time. View "Associated Press, et al. v. Second Judicial District, et al." on Justia Law

When asked about recent negative behavior, defendant-appellant Jason Roberts’ fifteen-year-old son informed his mother that she would understand if she saw the signs that Roberts “was sexually hurting” him. A Children at Risk Evaluation Services (CARES) facility interview was ultimately arranged for the child. At the beginning of the interview, the interviewer informed the child that he would speak to a nurse after the interview. Upon hearing this, the child appeared taken aback. The interviewer clarified that “they’re just going to see how tall you are and how much you weigh.” The child responded, “Okay, I thought they were going to test me for [sexually transmitted infections]. I was like, ummm.” During the CARES interview, the child detailed how Roberts had sexually abused the child starting when he was seven or eight years old. The child related that the last episode of sexual abuse occurred about two and one-half years prior to the CARES interview. While discussing the instances of sexual abuse, the child stated that after the abuse, he struggled with “suicidal stuff” that resulted in the child being “locked up.” The child indicated that after his release, he again struggled with “suicidal stuff” because the abuse continued. He admitted during the interview that he was having “a couple” thoughts about suicide, described his preferred method of self-harm, and indicated that at the time of the interview, he felt like engaging in self-harm a “little bit.” After the CARES interview, Roberts was indicted by a grand jury for two counts of lewd conduct with a minor child under age sixteen. At trial, the district court admitted a recording of the CARES interview over Roberts’ objection. In doing so, the district court found that the child was capable of making statements for medical purposes and that “there is little reason to doubt [the child’s] motivation in making the disclosures.” Both the child and Roberts testified at trial. Ultimately, the jury found Roberts guilty of both counts. Roberts appealed. Finding no abuse of discretion in admitting the CARES interview, the Idaho Supreme Court affirmed Roberts' judgment of conviction. View "Idaho v. Roberts" on Justia Law

Jane Doe appealed a district court’s decision to uphold the magistrate court’s judgment that Doe committed a battery—placing Doe within the purview of the Juvenile Corrections Act. Doe argued the magistrate court erred by using and applying the self-defense law reflected in Idaho Criminal Jury Instructions 1517 and 1518, instead of Idaho Code section 19-202A, Idaho’s “stand your ground” statute. Doe contended the statute’s legal standards differed from Instructions 1517 and 1518, and that the statutory standards should have been applied to her self-defense claim. To this, the Idaho Supreme Court disagreed: the "stand your ground" statute codified aspects of Idaho self-defense law that existed for over 100 years at common law, without abrogating those aspects it left uncodified. Thus, the Supreme Court held the district court did not err in upholding the magistrate court’s use and application of the pattern instructions, which presumptively reflected the elements of self-defense at common law. View "Idaho v. Jane Doe (2021-38)" on Justia Law

Respondent Camille Pool pleaded guilty to misdemeanor DUI in 2020. In May 2020, approximately two months following the onset of the coronavirus pandemic, Pool was sentenced at a hearing conducted over Zoom which she attended remotely. The State recommended Pool be sentenced to supervised probation with suspended jail time. The magistrate court ultimately sentenced Pool to 180 days in jail with 177 days suspended, granted her a withheld judgment, and placed her on supervised probation for 18 months. The magistrate court went on to explain some of the terms Pool would need to accept in order to receive probation. The following day, the magistrate court entered a written Judgment of Conviction: a form document for DUI cases. A paragraph next to the probation check box listed possible probation terms, which included: "Defendant specifically waives his/her 4th Amendment right to warrantless search of his/her person, vehicle, or residence by any law enforcement or probation officer." The form included a line for the defendant’s signature, but Pool was not personally present in the courtroom and, therefore, did not sign the Judgment. Instead, on the signature line, someone handwrote “mailed to defendant 5/27/2020.” While on probation, Pool failed to appear for drug and alcohol testing and failed to comply with other terms of her probation. On April 14, 2021, three probation officers went to Pool’s residence to conduct a residence check. One officer spoke with Pool, mentioned the Fourth Amendment waiver, and Pool indicated that she understood. Pool’s residence was searched and drugs and drug paraphernalia were found. Pool was charged with felony possession of a controlled substance and a misdemeanor charge for possession of drug paraphernalia. Pool moved to suppress the items seized and the statements she made during the search of her home, arguing that, among other things, she had not waived her right against search and seizure under Article I, section 17 of Idaho’s Constitution and, therefore, the search violated her rights under the Idaho Constitution. The Idaho Supreme Court determined the search was lawful and reversed the district court's decision granting the motion to suppress. View "Idaho v. Pool" on Justia Law