Justia Idaho Supreme Court Opinion Summaries

Robert Hansen pled guilty to the charges of aggravated driving under the influence and leaving the scene of an injury accident. At the sentencing hearing the district court allowed the victim's father to give an informal statement over Hansen's objection that the father was not a victim entitled to make a victim impact statement. The district court sentenced Hansen to a total of 15 years imprisonment for the two convictions. Hansen appealed. The Court of Appeals determined that it was error for the district court to allow the father’s statement, because the father was not a victim. However, the Court of Appeals held that any error was harmless. Hansen also appealed his sentences on both the aggravated driving under the influence charge and the leaving the scene of an injury accident charge, maintaining that the district court's departure from the plea agreement on one charge opened up both for review. The State petitioned this Court for review of whether the district court erroneously admitted the father’s statement. Upon review, the Supreme Court concluded the district court did nor err by admitting the victim's father's statement at the sentencing hearing, and it affirmed with regard to Hansen's sentence. View "Idaho v. Hansen" on Justia Law

In 2011, plaintiff-respondent Jamee Wade was shot twice by a Fruitland police officer after an altercation. Intending to file a claim under the Idaho Tort Claims Act, Wade sought copies of investigatory records related to the incident pursuant to the Idaho Public Records Act (IPRA). This appeal arose from a Petition for Access to Public Records filed by plaintiff seeking the disclosure of investigatory records in the possession of the Canyon County Prosecuting Attorney’s Office (CCPA). The district court ordered CCPA to produce the records pursuant to the request, but limited disclosure to Wade and his counsel. CCPA timely appealed. Upon review, the Supreme Court vacated the district court's judgment: the district court applied an erroneous legal standard in its analysis under I.C. 9-335. The records Wade requested were active investigatory records. View "Wade v. Taylor" on Justia Law

Defendant Alisha Murphy was convicted in 2001 of first degree murder of her husband, James. She appealed the conviction and sentence, which were affirmed in an unpublished opinion. Defendant filed a pro se application for post-conviction relief asserting numerous claims of ineffective assistance of counsel, police misconduct, prosecutorial misconduct, and judicial misconduct, together with a motion for the appointment of counsel. The Court of Appeals concluded defendant had made a successive petition for post-conviction relief and denied it. On appeal, defendant argued that the district court erred in denying her request for counsel, summarily dismissing her successive petition, and denying her I.R.C.P. 60(b) motion for reconsideration. She argued that her ineffective assistance of trial counsel claims were properly before the district court on successive petition because, under the Supreme Court’s decision in "Palmer v. Dermitt," (635 P.2d 955 (1981)), ineffective assistance of post-conviction counsel constituted sufficient reason to bring a successive petition under I.C. 19-4908. The Court of Appeals reversed in part and affirmed in part, concluding that the district court properly dismissed three out of the four ineffective assistance of counsel claims without appointing counsel. As to the remaining claim, the Court of Appeals held that defendant alleged sufficient facts to raise the possibility of a valid claim and remanded that claim to the district court for appointment of counsel. Defendant argued to the Supreme Court that she was entitled to relief from the district court’s orders denying counsel and summarily dismissing each of the claims in her successive petition. Upon review, the Supreme Court concluded that that ineffective assistance of post-conviction counsel was not a sufficient reason under I.C. 19-4908 for allowing a successive petition, and thus, overruled Palmer v. Dermitt. Accordingly, the Court of Appeals’ decision was reversed and the district court’s order of summary dismissal of defendant's successive petition for post-conviction relief was reinstated. View "Murphy v. Idaho" on Justia Law

Defendant-appellant Samuel Glenn appeals the district court’s denial of his motion to dismiss a 2010 driving under the influence (DUI) charge. The State sought an enhanced sentence based upon a 2001 DUI conviction. The district court had previously dismissed that 2001 DUI conviction. Defendant argued on appeal that the district court erred because Idaho Supreme Court precedent holds that cases dismissed pursuant to I.C. 19-2604 are a nullity and cannot later be used as sentencing enhancements. The State contended that the district court erred in considering the merits of Defendant's untimely motion to dismiss and that precedent allowed an enhanced sentence based on a previously dismissed DUI conviction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Glenn" on Justia Law

Alan and Diane Johnson were shot and killed in their home. The Johnsons' sixteen-year-old daughter Sarah was home at the time of the shooting. She consistently denied any involvement, but gave several different accounts of what she was doing, what she saw, and what she heard prior to and after the murders. After a lengthy trial, a jury found Johnson guilty of first-degree murder of her parents. The district court sentenced Johnson to concurrent life sentences, plus fifteen years for a firearm enhancement. Finding no reversible error, the Supreme Court affirmed her conviction and sentence. View "Johnson v. Idaho" on Justia Law

The issue before the Supreme Court in this case was a judgment dismissing an action wherein the plaintiff sought damages for injuries sustained as a result of contracting certain infections. The district court employed a differential diagnosis analysis and held that plaintiff's medical experts were required to rule out possible sources of the infections, other than the defendant's care. The district court determined that plaintiff's medical experts' opinions were inadmissible because they did not address the other possible sources of the infections that were suggested by defendant's medical expert. After its review, the Supreme Court concluded that the district court's determination was in error. Accordingly, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Nield v. Pocatello Health Services" on Justia Law

This appeal arose from the dismissal of a petition for adoption filed by Jane Doe, the long-time domestic partner of Jane Doe I. Jane Doe I is the legally recognized parent of the two children subject to the adoption: John Doe and John Doe I. The magistrate court dismissed on the grounds that "petitioner must be in a lawfully recognized union, i.e. married to the prospective adoptee's parent, to have legal standing to file a petition to adopt that person's biological or adopted child." The magistrate dismissed the petition "sua sponte, without any motion or opposition to the Petition, without prior notice to any of the affected parties, without inviting legal briefing, without any apparent consideration of the Pre-Adoptive Home Study and without hearing." A Final Judgment was entered the same day. Jane Doe moved for reconsideration, but before a ruling on that motion was made, I.A.R. 12.2 compelled her to file a Notice of Appeal to the Supreme Court. Upon review, the Supreme Court concluded the district court violated Jane Doe's rights to due process by dismissing the petition without the opportunity to be heard in a meaningful manner. Furthermore, the Court found that Idaho's adoption statutes unambiguously allow a second, prospective parent to adopt, regardless of marital status. Therefore, the Court reversed the district court's judgment and remanded the case for further proceedings. View "In the Matter of Adoption of John Doe" on Justia Law

The State appealed the district court’s decision to affirm the magistrate court’s holding that it did not have jurisdiction over John (2012-10) Doe because he was twenty-one years of age when the State filed its petition in juvenile court. Upon review, the Supreme Court reversed the decision of the district court. View "Idaho v. John Doe (2012-10)" on Justia Law

This appeal arose from an action filed against Defendant-Respondent Mallory Martinez, a National Guard member, by Plaintiff-Appellant William Teurlings. Plaintiff alleged he suffered personal injury and economic damage resulting from a vehicle collision caused by defendant's negligence. Defendant moved for summary judgment asserting immunity under I.C. 6-904(4), which provides immunity to National Guard members for claims arising out of certain federal training or duty. The district court granted the motion after concluding defendant fell within the scope of the statutory immunity. Teurlings appealed, arguing that defendant was not immune because she was not "engaged in training or duty" and she was not acting within the course of her employment at the time of the collision. Finding that the district court erred in granting defendant immunity, the Supreme Court vacated the judgment in her favor and remanded the case for further proceedings. View "Teurlings v. Larson" on Justia Law

Defendant-Appellant David Lee appealed the district court's order that denied his motion to strike certain language from his acquittal. In that judgment, the court declared that because defendant was "a serious pedophile, it is hoped that the authorities will be able to keep a closer watch on him in the future." Upon review, the Supreme Court concluded that the "surplus" language should not have been included in the judgment of acquittal in the first place when defendant raised the issue in his motion. That motion should have been granted. Therefore, the Supreme Court reversed the district court's denial of the motion to strike, and the case remanded for entry of an amended judgment eliminating the sentence in question. View "Idaho v. Lee" on Justia Law