Justia Idaho Supreme Court Opinion Summaries

This appeal arose from a termination of parental rights based on a Consent in Abeyance. The Idaho Department of Health and Welfare (IDHW) filed a Petition for the Termination of Parental Rights after a prolonged child protection proceeding involving John Doe and his two children, S.M. and C.M. In the Consent, Doe agreed to the conditional termination of his parental rights in exchange for the magistrate court vacating the hearing set on the termination petition and having his children returned to his care on an extended home visit. Doe was subsequently arrested and the magistrate court entered a judgment terminating Doe’s parental rights to both children on the grounds that Doe had signed the Consent and failed to substantially comply with its terms. Doe appealed. The Supreme Court held that Idaho does not recognize conditional consent to the termination of parental rights, and a termination of parental rights based on conditional consent is invalid. The magistrate erred by involuntarily terminating Doe’s parental rights without a showing by clear and convincing evidence of grounds for termination. Accordingly, the Court vacated the trial court's judgment and remanded the case for further proceedings. View "RE: Termination of Parental Rights" on Justia Law

Dale Piercy appealed the district court’s dismissal of his amended action for declaratory relief, which challenged the validity of a herd district ordinance enacted in 1982 by the Canyon County Commissioners. The district court dismissed Piercy’s claim on the basis that it was barred by a seven-year statute of limitations or, in the alternative, a four-year statute of limitations. Piercy challenged the application of both statutes, and argued that Respondents Jennifer Sutton, Luis Guzman, and Canyon County waived any statute of limitations defense. Upon review, the Supreme Court found no reversible error, and affirmed the district court. View "Guzman v. Piercy" on Justia Law

In 1994, an en banc panel of the district judges of the Fourth Judicial District ordered Garden City and Meridian to provide suitable and adequate quarters for the magistrate’s division of the Fourth Judicial District. In addition to providing quarters, the Cities were ordered to provide for the equipment, staff, supplies, and other expenses necessary for the quarters to function properly. The Cities have never complied with the order. In 2010, Ada County brought a declaratory action asking the district judges to find that the 1994 Order was still valid and to require the Cities to comply with it. The Cities responded by filing a motion to vacate the 1994 Order, claiming that the order was invalid because it was entered on an ex parte basis. The en banc panel dismissed Ada County’s complaint, holding that a declaratory judgment action was not the appropriate means to determine the validity of the 1994 Order. The panel also denied the Cities’ motion to vacate on the grounds that before the 1994 Order was entered, the Cities had received all the process to which they were entitled. The Cities appealed. Finding that the appeal did not present a justiciable controversy, the Supreme Court dismissed the appeal. View "Ada County v. Garden City" on Justia Law

Appellant Farmers National Bank (FNB) appealed the district court's grant of declaratory judgment in favor of Green River Dairy, LLC, and four commodities dealers: Ernest Carter, Lewis Becker, Jack McCall, and Hull Farms (Sellers). FNB argued the district court misinterpreted I.C. 45-1802 (a statutory lien provision) and as a result, erred in granting Sellers a priority lien on collateral securing a loan previously made by FNB. Upon review, the Supreme Court agreed with FNB about the misinterpretation and vacated the district court's grant of declaratory judgment in favor of the Sellers. View "Farmers Nat'l Bank v. Green River Dairy" on Justia Law

Rita Turner petitioned the magistrate court for a protection order for her and her son against her then-husband Robert Turner. The magistrate court found that there was reasonable cause to believe that bodily harm might result to Rita and her son and issued a 90-day order. Robert appealed to the district court, which affirmed the magistrate court’s decision. Robert then appealed that decision. Because Robert failed to develop an argument, offered scarce citation to authority, and ignored the aspects of the law unfavorable to him, the Supreme Court concluded he brought this appeal frivolously, unreasonably, or without foundation. View "Turner v. Turner" on Justia Law

BV Beverage Company, LLC appealed the dismissal of its petition regarding the expiration of its liquor license. Idaho Alcohol Beverage Control (ABC) contended that BV Beverage's interest in its license expired by operation of law when BV Beverage's lessee failed to timely renew. BV Beverage argued that the agency’s procedures deprived it of adequate procedural due process. The district court dismissed BV Beverage's petition because there was no agency action to review; even if there was agency action, the action did not violate procedural due process because BV Beverage had actual knowledge of the expiration date of the liquor license. Finding no reversible error, the Supreme Court affirmed. View "BV Beverage Company v. Idaho Alcohol Beverage Control." on Justia Law

Petitioner Erick Hall was convicted and sentenced to death twice: first for kidnapping, murder and rape; second for rape and murder. While Hall's petition for post-conviction relief was pending for his first sentence, his second trial for rape and murder was underway. During the overlap of Hall I and Hall II, there were numerous communications between Hall's trial attorneys representing him in Hall II, and the State Appellate Public Defender's (SAPD) office, handling Hall's post-conviction proceedings in Hall I. It was the communications between Hall's trial counsel that were the basis for a potential conflict of interest in this case, given that the issue before the Supreme Court in this appeal was ineffective assistance of trial counsel in his second petition for post-conviction relief. In 2008, Hall filed a petition for post-conviction relief in connection with his Hall II conviction. Two years later, the SAPD filed an Ex Parte Notice of Possible Conflict of Interest with the district court. The Ex Parte Notice stated that the SAPD had "cooperated with trial counsel in Hall II by sharing testing and expert information obtained in Hall I." Dennis Benjamin [. . .] agreed to evaluate the conflict and advise Mr. Hall whether or not the conflict should be waived." With no knowledge of the Ex Parte Notice, the State filed a Motion for Inquiry into Possible SAPD Conflict. Although Benjamin conducted an extensive inquiry into whether the SAPD was conflicted, the district court did not question Benjamin about his findings. Rather, the court believed that Benjamin was too closely aligned with the SAPD to be truly independent. The court then issued a Memorandum Decision and Order Appointing Keith Roark as Independent Counsel. The SAPD filed a Motion to Reconsider Memorandum Decision, which the court denied. On appeal, Hall acknowledged the trial court had an affirmative duty to inquire into a potential conflict whenever it knew or reasonably should have known that a particular conflict may exist. However, Hall argued that the cases relied on by the district court in finding that it had an affirmative duty to conduct a thorough and searching inquiry were distinguishable because the possibility of a conflict in this case was raised by Hall's counsel, not Hall himself. Additionally, Hall contended that Roark's conflict inquiry was unnecessary and duplicative because: (1) Benjamin assessed the possible conflict and concluded no conflict existed; and, (2) Benjamin made his conclusion after reviewing all relevant information. Further, Hall argued that the district court's second inquiry was unnecessary because the conduct of Hall's previous attorneys at the SAPD's office should not have been imputed to Hall's then-current post-conviction counsel. After its review, the Supreme Court concluded the district court erred in appointing Roark as independent counsel; the district court order granting Roark access to the SAPD's client file violated Hall's attorney-client privilege. Therefore the Supreme Court vacated the district court's order appointing Roark as independent conflict counsel and its order requiring the SAPD to pay for Roark's services. View "Hall v. Idaho" on Justia Law

This appeal arose from the termination of Jeffry Black, the former Executive Director of the Idaho Peace Officer Standards and Training Council (POST). Black asserted that the Idaho State Police (ISP) violated two provisions of the Idaho Protection of Public Employees Act ("the "Whistleblower Act") when it terminated him. The district court granted summary judgment in favor of ISP, holding that Black failed to engage in activity protected under the Act. Black appealed the district court's decision to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Black v. Idaho State Police" on Justia Law

Plaintiff Wade Frogley appealed the district court's grant of summary judgment in favor of Respondents Meridian Joint School District No. 2, Aaron Maybon, and Linda Clark, on Frogley's complaint of retaliation in violation of Title VII of the Civil Rights Act and the Idaho Human Rights Act. Plaintiff also appealed the district court's grant of summary judgment in favor of Respondents on his claim of negligent infliction of emotional distress. Plaintiff's claims stemmed from his work as an Assistant Principal at Mountain View High School within the Meridian School District. He alleged that within weeks of his hire, he was subject to continuous sexual harassment at the school from the principal and other assistant principals. Upon review, the Supreme Court concluded genuine issues of material facts existed with regard to both of Plaintiff's claims. As a result, the Supreme Court reversed the district court's judgment and remanded the case for further proceedings. View "Frogley v. Meridian Joint School Dist 2" on Justia Law

In 1991, appellant Zane Fields was sentenced to death for first degree murder. In 2011, appellant filed his sixth successive petition for post-conviction relief. He raised claims of actual innocence, prosecutorial misconduct, and violations of the right to counsel, due process, and the right to a fair trial. The district court granted the State's motion to dismiss appellant's petition because his claims were barred by I.C. 19-2719(5). Appellant appealed the district court's dismissal of his petition. Finding no reversible error, the Supreme Court affirmed. View "Fields v. Idaho" on Justia Law