Justia Idaho Supreme Court Opinion Summaries

Defendant-appellant Joshua Jones appealed his conviction for grand theft by extortion. Defendant argued the district court erred when it denied his mid-trial request to question a juror after the juror informed the court that he was suffering from anxiety and was unsure if he could continue participating on the jury. Defendant also argued that the district court made errors in evidentiary rulings and that the prosecutor engaged in various forms of misconduct during closing argument. The Court of Appeals vacated the judgment of conviction, and remanded the case for a new trial. The State appealed the appellate court's judgment. It is reasonable to assume that after the trial resumed, the court, defense counsel, and bailiff may have continued to observe Juror 69 for any outward signs of anxiety. Because no further concerns were raised by anyone, including Juror 69, this Court is not in a position to second guess the district court’s handling of the matter. For these reasons, we conclude that the district court did not abuse its discretion in dealing with the matter. The Court affirmed the district court in all other respects. View "Idaho v. Moses" on Justia Law

Bob Boren appealed his conviction entered upon his conditional guilty plea to unlawful possession of a firearm. Boren claimed that the district court erred in denying his motion to dismiss the charge. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Boren" on Justia Law

Two cases were consolidated on appeal. In the first case, Defendant was convicted of felony attempting to elude a peace officer, and misdemeanors malicious injury to property and assault. In the second case, Defendant was convicted of felony grand theft. For each felony, he was sentenced to eighteen years in prison, with eight years fixed and ten years indeterminate, and the sentences were ordered to be served consecutively. Defendant raised five alleged errors in connection with his eluding case, and two alleged errors in the grand theft case. Taking each in turn, but finding no reversible error, the Supreme Court affirmed Defendant's convictions. View "Idaho v. Skunkcap" on Justia Law

The Board of Trustees of the Mountain Home School District No. 193 appealed the district court’s denial of the its request for attorney fees. This case arose when School District employee Terri Sanders claimed that the Board breached its contract with her by hiring a candidate less qualified than her for a teaching position that Sanders had also applied for. After a jury found the Board did not breach its contract, the district court held the Board was not entitled to attorney fees because Sanders presented a legitimate issue for trial. The court also held that because I.C. 12-117 was the exclusive source of attorney fees for a school district, I.C. 12-120(3) could not apply. Upon review, the Supreme Court concluded that attorney fees under I.C. 12-117 were not exclusive. Because fees were available under I.C. 12-120(3), the Court remanded the case for the district court to enter the appropriate award of attorney fees under that statute. The Court also vacated the district court’s award of arbitration costs to the Board. Neither party received attorney fees on appeal. View "Sanders v. Bd of Trustees - Mt. Home School Dist 193" on Justia Law

The State charged defendant-appellant Russell Parker with one count of lewd and lascivious conduct with a minor under sixteen. Defendant went to trial and the jury found him guilty. On appeal to the Supreme Court, defendant argued that the district court erred in admitting statements made by law enforcement during an interview with him. Further, he argued that the State engaged in five instances of prosecutorial misconduct, each satisfying the fundamental error standard, and these in the aggregate resulted in cumulative error. Due to these errors, defendant asked that the Court vacate his conviction and remand his case for a new trial. Finding no reversible error, the Supreme Court affirmed defendant's conviction. View "Idaho v. Parker" on Justia Law

Defendant-appellant Krystal Easley appealed the revocation of her probation and the Supreme Court's partial denial of her request to augment the record with various transcripts to be created at the public's expense. This case also presented the issue of the prosecutor's refusal to consent to the district judge's desire to sentence Easley to mental health court and the district court's acquiescence in that refusal. Defendant has been charged by information with possession of a controlled substance. She admitted to violating the terms of her probation for failing to stay in contact with her probation officer, moving without permission and failing to pay for the costs of her supervision. Defendant had been in contact with a mental health court coordinator. Defendant asserted that she was a good candidate for mental health court. The prosecutor did not agree with the recommendation. The district court ruled it did not have the authority to place defendant into the mental health program because the prosecutor had an "absolute veto" over post-judgment eligibility for mental health court. Upon review, the Supreme Court concluded: (1) it did not violate defendant's right to due process and equal protection when it denied in part her motion to augment; (2) the district court erred in sentencing when it determined that the prosecutor had an absolute right to veto the district court's desired decision to sentence defendant to the mental health court; and (3) the district court erred when it failed to consider the mental health court as an alternative in sentencing when it revoked defendant's probation. The case was remanded for further proceedings. View "Idaho v. Easley" on Justia Law

Defendant-respondent Carey Baker married Robyn Shea in 2005; divorced in 2009. Shortly thereafter, Shea sought and obtained a civil protection order against Baker. Shea received a series of phone messages from Baker in violation of the protection order. Eleven of those phone messages were received by Shea while she was located in Kootenai County, and one of the messages was received by Shea while she was located in Ada County. The Boise City Attorney, acting on behalf of the City of Meridian, filed a misdemeanor complaint against Baker for one count of violating the protection order for the phone message Shea received while in Ada County. The Coeur d'Alene City Attorney in Kootenai County filed charges against Baker for twelve counts of violating the protection order for all of the phone messages that Shea received from Baker. Kootenai County also issued an arrest warrant on the same day. On February 27, 2010, Baker entered into a plea agreement with the Boise City prosecutor, agreeing to plead guilty to the single count filed in Ada County in exchange for the promise that "the State" would pursue no other charges against him for violation of the protection order for calls Baker placed to Shea prior to February 17, 2010. At sentencing, the magistrate judge considered all twelve phone messages that Shea received from Baker. This included the messages that were the basis of the charges in Kootenai County. The Boise City Attorney was aware of the phone calls to Kootenai County but unaware charges had been filed. Likewise, the Coeur d'Alene City Attorney was not aware of the proceeding in Ada County. On April 2, 2010, Baker was arrested on the warrant issued in Kootenai County. On October 8, 2010, Baker filed a motion to dismiss the charges in Kootenai County claiming double jeopardy and violation of the plea agreement. On November 5, 2010, the magistrate judge dismissed one count of the charges in Kootenai County because that charge was for the August 24, 2009, phone message to which Baker pled guilty in Ada County. The magistrate judge denied Baker's motion to dismiss the remaining eleven counts. A jury ultimately found Baker guilty on all eleven counts of violating the protection order. Baker appealed to the district court in its capacity as an intermediate appellate court, asserting that the Coeur d'Alene City Attorney was bound by the plea agreement between him and the Boise City prosecutor. The district court vacated the convictions in Kootenai County on the basis that the Coeur d'Alene City Attorney was bound by the terms of Baker's plea agreement. The district court ruled that the plea agreement must be construed in favor of Baker and that specific performance of the plea agreement was the appropriate remedy. The State appealed. Finding no reversible error, the Supreme Court affirmed the district court's decision vacating the eleven Kootenai County charges. View "Idaho v. Baker" on Justia Law

A certified question of law from the U.S. District Court for the District of Idaho was presented to the Idaho Supreme Court. Karen White and her development company, Elkhorn, LLC, sought to recover $166,496 paid to Valley County for "capital investments for roads in the vicinity of [their] White Cloud development." Phase I of White Cloud was completed and it was undisputed by the parties that the tax monies paid for Phase I were used by the County to complete capital investments for roads in the vicinity of the White Cloud development. The County conceded that it did not adopt an impact fee ordinance or administrative procedures for the impact fee process as required by the Idaho Development Impact Fees Act (IDIFA). The County also conceded it did not enact an IDIFA-compliant ordinance, because, at the time, the County believed in good faith that none was required. Plaintiff filed suit against the County claiming that the road development fee imposed by the County as a condition for approval of the White Cloud project violated Idaho state law and deprived Plaintiff of due process under both the federal and Idaho constitutions. In her Second Amended Complaint, Plaintiff raised two claims for relief. The first claim for relief alleged that “Valley County’s practice of requiring developers to enter into a Road Development Agreement ("RDA," or any similar written agreement) solely for the purpose of forcing developers to pay money for its proportionate share of road improvement costs attributable to traffic generated by their development is a disguised impact fee, is illegal and therefore should be enjoined." The first claim for relief also alleged that, because the County failed to enact an impact fee ordinance under IDIFA, the imposition of the road development fees constituted an unauthorized tax. Plaintiff’s second claim for relief alleged that the County’s imposition of the road development fee constituted a taking under the federal and Idaho constitutions. The County argued Plaintiff voluntarily agreed to pay the RDA monies. Plaintiff denies that the payment was voluntary since it was required to obtain the final plat approval. The issue the federal district court presented to the Idaho Supreme Court centered on when the limitations period commences for statutory remedies made available under Idaho law to obtain a refund of an illegal county tax. The Court answered that the limitations period for statutory remedies made available under Idaho law to obtain a refund of an illegal county tax commences upon payment of the tax. View "White v. Valley County" on Justia Law

Medical Recovery Services, LLC (MRS), a licensed collection agency, appeals from the district court’s order affirming default judgments entered by the magistrate court. Each Respondent’s account indebtedness was assigned to MRS. MRS filed suit to recover payment from each Respondent and also sought $350 in attorney fees from each, based on a contractual provision. None of the Respondents answered the complaints filed by MRS, so MRS filed for default judgments to be entered in each case. The magistrate court entered default judgments as to all Respondents but granted attorney fees in amounts less than the $350 that MRS was requesting under the contracts. MRS asserted that the magistrate erred in awarding attorney fees in the amount of the principal owed by the Respondents for medical services, as opposed to $350, which was the minimum amount that each Respondent contracted to pay. Finding no reversible error, the Supreme Court affirmed the district court. View "Medical Recovery Services v. Strawn" on Justia Law

Jeffrey Murray appealed the district court's order dismissing his petition for post-conviction relief after he pled guilty to felony domestic violence and was sentenced to three years fixed followed by seven years indeterminate. Murray's petition for post-conviction relief argued, among other things, that he received ineffective assistance of trial counsel. Upon review, the Supreme Court affirmed the district court's dismissal of Murray's petition for post-conviction relief: "although Murray has provided argument that his counsel was deficient in failing to inform him of his ability to obtain a confidential domestic violence evaluation prior to pleading guilty, he has not provided a single authority or legal proposition to support his argument. Murray merely states, without support, that his counsel’s failure to advise him of his ability to undergo a confidential evaluation 'represented deficient performance.'" View "Murray v. Idaho" on Justia Law