Justia Idaho Supreme Court Opinion Summaries

The State appealed a district court’s order granting John Joseph Marr’s petition for post-conviction relief based on ineffective assistance of counsel at trial. Marr was arrested and charged with felony attempted strangulation and domestic battery with a traumatic injury. A jury found Marr not guilty as to the attempted strangulation but guilty of domestic battery with a traumatic injury. Marr’s direct appeal was unsuccessful and he filed a petition for post-conviction relief based on ineffective assistance of counsel at both trial and at sentencing. After a post-conviction evidentiary hearing, the district court found Marr’s attorney was ineffective at trial for failing to discover and admit evidence of the victim’s reputation for belligerence and aggression when intoxicated and for failing to elicit testimony from the victim about whether she had consumed alcohol before testifying. The district court granted Marr’s petition for relief as to trial, vacating Marr’s conviction. The district court denied Marr’s petition for post-conviction relief as to sentencing. The Court of Appeals reversed the district court’s grant of post-conviction relief. The Idaho Supreme Court granted Marr’s petition for review, and affirmed the district court’s order granting Marr’s petition for post-conviction relief. View "Marr v. Idaho" on Justia Law

In a consolidated appeal from Ada and Blaine County district court, the issue before the Idaho Supreme Court centered on credit for time served under Idaho Code section 18-309. Marco Antonio Rios-Lopez and Corey Dale Young (collectively, Appellants) sought credit for time served under the construction of section 18- 309, pronounced in Idaho v. Owens, 343 P.3d 30 (2015). The district courts denied Appellants’ motions, and the Court of Appeals affirmed. The district courts in both cases held that Appellants were not entitled to relief under Owens because their judgments of conviction had become final before Appellants filed their Rule 35 motions. Appellants do not contend they were sentenced incorrectly under Idaho v. Hoch, 630 P.2d 143 (1981). Rather, they sought relief under Owens, where, nearly 34 years after Hoch, the Idaho Supreme Court pronounced a different construction of section 18-309 and overruled Hoch. The Supreme Court expressed the construction of section 18-309 pronounced in Owens would apply “only prospectively and to cases now on [i.e., as of February 9, 2015] direct review.” Since Appellants’ judgments of conviction were final before Owens was decided, Appellants were not entitled to relief under Owens. View "Idaho v. Young" on Justia Law

Kody Gibbs appealed a district court’s order extending his probation. In 2013, Gibbs was charged with delivery of a controlled substance after he sold methamphetamine to a minor. Pursuant to plea negotiations, Gibbs pled guilty to delivery of a controlled substance, and the district court dismissed allegations that the delivery was to a minor and that Gibbs was a persistent violator. The district court imposed a suspended sentence of fifteen years, with ten years fixed, and placed Gibbs on probation for five years. One condition of Gibbs’ probation required him to successfully complete mental health court. In the subsequent years, Gibbs got in trouble by taking prohibited drugs, drinking, and committing felony sexual exploitation of a child. Gibbs would also be indicted by a federal grand jury for possessing child pornography. Gibbs argues on appeal of his state charges that: (1) he was denied his constitutional right to due process because his case was not heard by an impartial judge; and (2) the district court abused its discretion by increasing, sua sponte, his probation from a term of six years to life. Finding no abuse of discretion or reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Gibbs" on Justia Law

Gilberto Garza, Jr., appealed a district court’s dismissal of his petitions for post-conviction relief. Garza signed two plea agreements relating to charges of aggravated assault and possession of a controlled substance with intent to distribute. As part of his plea agreements Garza waived his right to appeal. Despite the waivers, Garza instructed his attorney to appeal. Garza’s attorney declined to file the appeals, citing the waivers of appeal in the plea agreements. Garza then filed two petitions for post-conviction relief on his own, alleging his counsel was ineffective for failing to appeal. The district court dismissed Garza’s petitions concluding Garza’s counsel was not ineffective in failing to appeal. The Court of Appeals and the Idaho Supreme Court agreed and affirmed. View "Garza v. Idaho" on Justia Law

In 2016, the Economic Advisory Council (“the EAC”), a body created under authority of Idaho Code section 67-4704, granted a tax credit of $6.5 million to Paylocity, an Illinois corporation. Employers' Resource Management ("Employers") complaint alleged that this tax credit was a governmental subsidy to Paylocity that would give it a competitive advantage over Employers. Employers challenged the Idaho Reimbursement Incentive Act ("IRIA") program as unconstitutional, alleging that the Legislature unconstitutionally delegated its authority over tax matters to the Executive Branch. The district court dismissed Employers' complaint for declaratory relief for lack of standing. The district court’s rejection of Employers’ claim of competitor standing was, in part, based upon its view that “even when competitor standing has been recognized, ‘it is only when a successful challenge will set up an absolute bar to competition, not merely an additional hurdle, that competitor standing exists.’ ” The Idaho Supreme Court was not persuaded that view was an accurate statement of the law of competitor standing, and vacated the district court's judgment.The case was remanded for further proceedings. View "Employers Resuorce Mgmt Co v. Ronk" on Justia Law

Kenneth and Donna Johnson appealed a district court judgment recognizing a tribal judgment from the Coeur d’Alene Tribal Court (Tribal Court). The Johnsons owned land within the Coeur d’Alene Reservation (Reservation) on the banks of the St. Joe River and had a dock and pilings on the river. The Coeur d’Alene Tribe (Tribe) initiated an action in Tribal Court to enforce a tribal statute which required a permit for docks on the St. Joe River within the Reservation. The Johnsons did not appear and a default judgment was entered against them. The judgment imposed a civil penalty of $17,400 and declared that the Tribe was entitled to remove the dock and pilings. On January 2016, the Tribe filed a petition to have the Tribal Court judgment recognized in Idaho pursuant to the Enforcement of Foreign Judgments Act. I.C. sections 10-1301, et seq. The district court held the Tribal Judgment was valid and enforceable, entitled to full faith and credit. However, the Idaho Supreme Court determined the district court was incorrect in holding the Tribal Judgment was entitled to full faith and credit, and the civil penalty was not entitled to recognition in Idaho courts. However, the Idaho Supreme Court held the Tribal Court had jurisdiction over the Johnsons and the subject matter of this case; the Johnsons did not meet their burden of establishing the Tribal Court did not have jurisdiction, and the Johnsons were afforded due process in Tribal Court. In this case the judgment comprised two parts: (1) the civil penalty of $17,400; and (2) the declaration that the Tribe had the right to remove the offending encroachment. The civil penalty was not enforceable under principles of comity. However, the penal law rule does not prevent courts from recognizing declaratory judgments of foreign courts. Therefore, the Idaho Supreme Court vacated the district court’s judgment to the extent that it recognized the Tribal Court’s judgment imposing the civil penalty of $17,400. The Court affirmed the judgment recognizing the Tribal Court judgment regarding the Tribe’s right to remove the dock and pilings. View "Coeur d' Alene Tribe v. Johnson" on Justia Law

Manwaring Investments, L.C., owner of a commercial building in the City of Blackfoot, appealed a district court order granting summary judgment to the City. Manwaring sued the City in October 2014, alleging the City was overcharging it for wastewater utilities ​and stopped paying the disputed portion of fees. Manwaring’s complaint alleged that the assessment of two Equivalent Dwelling Units (EDUs) on the Building: (1) violated the Idaho Revenue Bond Act; (2) constituted an unconstitutional tax; and (3) violated due process. In addition to requesting a declaratory judgment and an injunction, Manwaring requested damages in the amount of $1,803.66, which reflected the amount Manwaring allegedly overpaid for wastewater utilities. The magistrate granted the City’s motion for summary judgment. Manwaring moved for reconsideration, which the magistrate denied. Manwaring then appealed the magistrate’s rulings to the district court, which affirmed the magistrate. Manwaring timely appeals the decision of the district court. Finding no reversible error, the Idaho Supreme Court affirmed. View "Manwaring Investments, L.C. v. City of Blackfoot" on Justia Law

Trevor Lee appealed a district court’s denial of his motion to suppress evidence. As part of his plea agreement, Lee reserved the right to challenge the denial of his suppression motion on appeal. The district court concluded the pat-down frisk was reasonable under Terry v. Ohio, 392 U.S. 1 (1968), but the officer exceeded the scope of the frisk by opening the containers found in Lee’s pocket. However, the district court concluded the search of the containers was permissible as a search incident to Lee’s arrest because, prior to the search, the officer had probable cause to arrest Lee for driving without privileges and the search was substantially contemporaneous with the arrest. The court of appeals agreed and affirmed the district court’s denial of Lee’s motion to suppress. The Idaho Supreme Court found after review: (1) the district court correctly concluded that the frisk was justified under Terry but that the arresting officer exceeded the scope of a permissible frisk when he opened the containers found on Lee; and (2) the district court therefore erred in concluding the search of Lee's person was a permissible search incident to arrest. The Court vacated the conviction, reversed the district court’s denial of Lee’s motion to suppress, and remanded for further proceedings. View "Idaho v. Lee" on Justia Law

Defendant-appellant Jonathan Folk was convicted by jury on one felony count of sexual abuse of a child under sixteen years old. On appeal, Folk contended the district court made numerous evidentiary errors. Folk also argued that the district court erred by denying his motion for a judgment of acquittal and the prosecutor committed misconduct amounting to fundamental error in his closing argument. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Folk" on Justia Law

Darol Anderson appealed his convictions for felony domestic battery and misdemeanor domestic battery, arguing the district court erred when it admitted the preliminary hearing testimony of his alleged victim, Erica Messerly, after finding that she was unavailable to testify at his trial due to mental illness. Anderson also argued the district court abused its discretion when it allowed a responding officer to testify that the injuries that he had observed on Messerly’s person were consistent with her allegations against Anderson. Anderson contended the officer’s testimony constituted impermissible vouching for Messerly’s truthfulness. The Idaho Supreme Court found the district court erred in admitting Messerly’s testimony from the preliminary hearing in this case because the State failed to establish Messerly was unavailable to testify. The Court affirmed the conviction in all other respects. View "Idaho v. Anderson" on Justia Law