Justia Idaho Supreme Court Opinion Summaries

The City of Hayden provided sewer service to the residents living in the City and to some persons living outside the City. To do so, the City entered into a joint powers agreement with the Hayden Area Regional Sewer Board, which operated a regional wastewater treatment plant serving the City and two other local entities. The City charged each customer it serves a bi-monthly fee, which covered a proportionate share of the operation and maintenance of the City's sewer collection system and of the operation and maintenance costs associated with the regional wastewater treatment facility. In addition to the bi-monthly fee, the City charged a one-time "sewer capitalization fee" for each new structure, whether residential or commercial, and for any addition to an existing commercial structure that would result in an increase in the volume of sewage generated. The capitalization fee was charged when a building permit is issued. In March 2006, the City contracted with an engineering company to update the City's sewer master plan. The engineering company submitted a capital improvement plan in which it recommended forty projects that would cost about $20 million in order to replace existing infrastructure and to construct new infrastructure so that the sewer system would reach the entire area of city impact and accommodate anticipated future population growth. In order to finance the project, the engineering company recommended that the part of the capitalization fee retained by the City be increased from $735 for one equivalent residence ("ER") to $2,280 for one ER. In 2010, the North Idaho Building Contractors Association filed suit to have the fee declared unlawful because it was an impermissible tax rather than a fee for services. The district court held that it was lawful and entered a judgment dismissing the complaint. The City requested an award of attorney fees, which the court denied. The Contractors Association appealed the dismissal of its complaint, and the City cross-appealed the denial of an award of attorney fees. Because there was nothing in the record showing that as of June 7, 2007, the sum of $2,280 was the actual cost of providing sewer service to a customer connecting to the City sewer system and there was no showing that the amount of the fee was based upon any such calculation, the fee was not authorized by Idaho Code section 63-1311(1). The Supreme Court concluded the district court erred in holding that it was. View "No. Idaho Bldg Contractors Assoc. v. City of Hayden" on Justia Law

William Wolfe appealed the Idaho County district court’s decisions denying: (1) his motion for a hearing on his motion for reconsideration of his I.C.R. 35 motion to correct an illegal sentence; and (2) his successive Rule 35 motion to correct an illegal sentence. Specifically, Wolfe argued the district court denied his motions based on two erroneous conclusions: that the subject matter jurisdiction issue had been previously adjudicated and that Wolfe could not file a successive Rule 35 motion. Wolfe argued that if the district court had properly considered the merits of his motions, the district court would have found it lacked subject matter jurisdiction over Wolfe’s original criminal proceedings. Accordingly, Wolfe petitioned the Supreme Court to vacate his judgment of conviction and sentence, or alternatively, to remand the case for an evidentiary hearing. After careful consideration of the district court record, the Supreme Court found no reversible errors, and affirmed the district court’s decisions denying Wolfe’s motion for a hearing and his successive Rule 35 motion. View "Idaho v. Wolfe" on Justia Law

The issue this appeal presented for the Supreme Court's review arose from a district court’s denial of Dameniel Owens’s motion for credit for time served. The district court specified that Owens would only receive credit for his prejudgment time served in a county jail on one of his eight counts of issuing a check without funds. Owens argued that Idaho Code section 18-309 plainly and unambiguously required the district court to credit his prejudgment time served to each of his eight counts. Owens further argued that the Supreme Court should have overruled "Idaho v. Hoch," (630 P.2d 143 (1981)), because in that case the Court improperly went beyond the statute’s plain meaning to hold that the legislature intended a defendant could not receive credit for each separate crime. The Supreme Court indeed overruled "Hoch," vacated the district court’s order denying Owens’s motion for credit for time served, and remanded the case for further proceedings. View "Idaho v. Owens" on Justia Law

Defendant David Knutsen appealed a jury verdict finding him guilty of four counts of sexual abuse of a vulnerable adult. Defendant argued on appeal that the term of the grand jury that indicted him had already expired, that the statute defining the crimes was unconstitutional, that there was insufficient evidence to support the jury’s verdict, and that his conviction should be for only one count because his conduct constituted one continuous act. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Knutsen" on Justia Law

A jury found defendant Joseph Thomas, Jr. guilty of first degree murder for the strangulation death of his ex-wife, Beth Irby Thomas in 2011. A friend of Defendant testified that at about 12:30 a.m. the following day, Defendant came to the friend’s home and stated that he had strangled the decedent. After Defendant left, the friend called 911. The first police officer to arrive at the decedent’s home found her with a leather belt cinched tightly around her neck. The belt was Defendant’s, and he was standing outside her house when the police arrived. After review of defendant's arguments on appeal, the Supreme Court concluded that because the district court erroneously excluded evidence that could have corroborated the defendant’s version of what had occurred and the State did not show that such error was harmless, the Court vacated the jury verdict and the judgment and remanded this case for further proceedings. View "Idaho v. Thomas" on Justia Law

In 2012, Idaho State Police stopped defendant-respondent Derek Arrotta for a traffic violation. At the end of the stop, defendant was issued a citation for misdemeanor driving while under the influence of alcohol. Defendant filed a motion to suppress “based on violations of the defendant’s right to be free from unreasonable search and seizure, right to remain silent, right to counsel, and related constitutional protections under the State of Idaho Constitution and the United States Constitution,” but the motion did not identify what evidence he wanted to suppress or how his rights were allegedly violated. The parties agreed to postpone the matter until the United States Supreme Court decided "Missouri v. McNeely." After the Supreme Court issued its opinion in McNeely, the magistrate court held an evidentiary hearing on the motion to suppress. The trooper testified to the events and stated that he did not recall telling Defendant that he did not have a right to refuse the blood test. However, he also testified that he told Defendant that if he refused the breath test, the trooper would get a blood draw. Defendant testified that he refused the breath test, but not the blood test. He testified that at the hospital he asked if he could refuse the blood test, “but they pretty much said no.” When asked if the trooper told Defendant he could not refuse the blood draw, Defendant answered, “Yeah, something to that extent.” The magistrate court did not resolve the factual dispute regarding whether Defendant was told that he could not refuse the blood draw. Rather, it held that statutory implied consent was insufficient by itself to constitute consent to a search in the form of a blood draw; that express consent was required. Based upon that holding, the court granted Defendant’s motion and issued an order suppressing the blood test results. The State appealed to the district court. The district court affirmed the suppression order, holding that statutory implied consent to a blood draw is revocable. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Arrotta" on Justia Law

In 2012, a Post Falls police officer was searching for a gray truck with stolen Washington license plates. He located and began to follow the truck, and he confirmed that the license plate on it was stolen. The truck stopped in a parking lot in Post Falls, and the officer told the driver, later identified as defendant Dennis Halseth, to stay in the vehicle. Defendant drove away, with the officer in pursuit. Defendant was later stopped and arrested in Washington by a Washington state trooper. The trooper asked Defendant to complete voluntary field sobriety tests, and Defendant refused. The trooper then transported Defendant to a hospital in Spokane, Washington, to have his blood drawn for evidentiary testing. Despite defendant's protests, the hospital technician drew blood samples from each of defendant’s arms. No search warrant was obtained prior to the blood draws. The State of Idaho charged defendant with several crimes including driving while under the influence of alcohol, which would be a felony because of his prior convictions. Defendant moved to suppress the evidence on the ground that he did not consent to the warrantless search. He did not contend that the trooper lacked probable cause to believe that he had been driving under the influence of alcohol. In light of the decision of the United States Supreme Court in "McNeely," the State did not argue that the natural dissipation of alcohol in the bloodstream was an exigent circumstance justifying a warrantless search, nor did it argue that there were any other exigent circumstances justifying the search. The State argued that both Washington and Idaho had statutes providing that persons who drove on public roads impliedly consented to a test for alcohol concentration in their blood; and that Idaho case law held that there was no legal right to withdraw that implied consent; and that the implied consent included a blood draw. The district court granted the motion to suppress, and the State appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Halseth" on Justia Law

Defendant Juan Luis Sanchez-Castro was indicted, tried, and convicted of one count of conspiracy to traffic in 400 grams or more of methamphetamine and one count of trafficking in 400 grams or more of methamphetamine. For each crime, he was sentenced to fifteen years in the custody of the Idaho Board of Correction, with the first ten years fixed and the remaining five years indeterminate, and a fine of $25,000. The district court ordered that the prison sentence on the second charge run concurrently with the prison sentence on the first charge. Defendant appealed, arguing that the conspiracy charge and the trafficking charge were, under Idaho law, the same charge. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Sanchez-Castro" on Justia Law

The Kootenai County Prosecutor filed a two-count information against Jesse Elias alleging that he committed forcible sexual penetration by use of a foreign object (to a minor child), and burglary. The matter proceeded to trial and the jury found Elias guilty of both counts. Elias was sentenced to fifty years imprisonment, with ten years fixed for the first charge; for burglary, Elias received a concurrent ten year fixed sentence. The district court retained jurisdiction for one year. At the completion of the retained jurisdiction, the district court suspended the sentences and placed Elias on probation for fourteen years. Elias appealed, and the Court of Appeals found insufficient evidence of use of force to sustain Elias’ conviction for forcible penetration by a foreign object. The issue presented by this appeal was whether the State produced sufficient evidence at trial to support the jury’s finding that Elias was guilty of forcible sexual penetration by use of a foreign object. The outcome of this appeal turned upon what the Legislature intended when it used the word “force” in Idaho Code section 18-6608. Upon review, the Court reversed the judgment of conviction for forcible penetration by a foreign object and remanded for further proceedings to modify the length of Elias’ probation. View "Idaho v. Elias" on Justia Law

Gary Schall was arrested for driving under the influence of alcohol. He had two prior convictions for driving under the influence within the previous ten years, one of which stemmed from a 2004 arrest in Wyoming. As a result of his prior convictions, the State enhanced his DUI charge to a felony. At the preliminary hearing, the magistrate found that there was probable cause to bind the case over to district court. Schall filed a motion to dismiss in the district court, arguing that the State had the burden at the preliminary hearing to provide probable cause to believe his Wyoming DUI conviction was for a "substantially conforming foreign criminal violation," that the State failed to meet that burden, and that the Wyoming conviction was not in fact a substantially conforming violation. The district court denied Schall's motion, finding that the State met its burden at the preliminary hearing and that the Wyoming statute substantially conformed to Idaho's DUI statute. Schall appealed and the Court of Appeals reversed. The State appealed, and now the Supreme Court reversed, concluding the district court correctly denied Schall's motion to dismiss. View "Idaho v. Schall" on Justia Law