Justia Idaho Supreme Court Opinion Summaries

The issue before the Supreme Court in this case related to the service of four members of the Board of Directors for the Southern Valley County Recreation District. The State brought usurpation actions against Donald Keithly, Yvette Davis, Patrick Cowles, and Michael Smith (the Directors), alleging they usurped their offices as directors of the Recreation District. The State requested they be removed from office and sought a fine against each of them. Upon the parties' cross-motions for summary judgment, the district court ruled that this action was an election contest, rather than a usurpation action, which could be brought by the State. The district court also ruled that the Directors' actions while in office were protected by the de facto officer doctrine. The State appealed, arguing this was a proper usurpation action and the de facto officer doctrine did not apply. The Directors cross-appealed, arguing they are entitled to attorney fees. The Supreme Court concluded the matter was moot and affirmed the district court's order denying attorney fees. View "Idaho v. Keithly" on Justia Law

The issue on appeal before the Supreme Court in this case arose from an order denying an employer's motion to have a laptop returned that had been seized from its employee during a search conducted at the employee's home by a probation officer. The Court affirmed the order denying the return of the laptop, but held that the laptop could not be searched without a search warrant issued upon a judicial finding of probable cause. View "Idaho v. Ruck" on Justia Law

The issue on appeal before the Supreme Court arose from a district court order that denied Defendant's motion to dismiss for the lack of probable cause, a felony charge of possession of methadone. The methadone was discovered upon the birth of the defendant's baby girl in the umbilical cord. Upon review of the matter, the Supreme Court held that for the purposes of determining whether there was probable cause to believe that the defendant had possessed a controlled substance, the magistrate judge could reasonably have inferred that the defendant consumed the methadone; that she possessed it before she consumed it; and that she knew it was either methadone or a controlled substance when she was possessing it. View "Idaho v. Neal" on Justia Law

Defendant Todd Carver was convicted of murdering the three-year-old son of his live-in girlfriend. He appealed, arguing that the district court erred in failing to appoint substitute counsel for him, in its instructions to the jury defining the crime, and in calculating his sentence. Finding no reversible error, the Supreme Court affirmed defendant's conviction and sentence. View "Idaho v. Carver" on Justia Law

Defendant-Appellant Jose Brunet appealed a district court's order relinquishing jurisdiction and denying his oral motion requesting leniency pursuant to Rule 35 of the Idaho Criminal Rules. Appellant also argued that the Supreme Court's order denying his motion to augment the appellate record violated his constitutional rights to due process and equal protection, and would deny him effective assistance of counsel on appeal. Upon review of the matter, the Supreme Court affirmed the district court's order and held that appellant failed to show that the denial of his motion to augment the appellate record with additional transcripts violated his constitutional rights. View "Idaho v. Brunet" on Justia Law

The issue before the Supreme Court in this case concerned the district court’s holding that Ashton Urban Renewal Agency (AURA) had standing to challenge a property tax exemption granted to Ashton Memorial, Inc., a corporation with real and personal property located within AURA’s revenue allocation area. Specifically, the issue was whether AURA was a “person aggrieved” under I.C. 63-511, and therefore, could appeal the grant of the exemption to the Idaho Board of Tax Appeals (BTA). The Supreme Concluded that AURA was an "person aggrieved" under the statute, therefore it affirmed the district court's decision. View "Ashton Urban Renewal v. Ashton Memorial" on Justia Law

Defendant-Appellant Joseph Clinton was indicted for felony lewd conduct with a minor under sixteen. Initially he was found incompetent to stand trial, but after reassessment, he was deemed competent. Thereafter he pled guilty, and underwent further assessment prior to receiving sentence. The sentencing court ultimately sentenced defendant to twenty years' incarceration, three years fixed and the remainder indeterminate. Defendant moved for reduction of the sentence, which was denied. The Court of Appeals affirmed defendant's sentence. The issues on appeal to the Supreme Court were: (1) whether the trial court erred in failing to order a mental evaluation sua sponte; and (2) whether the sentencing court abused its discretion in imposing defendant's ultimate sentence. Finding no errors, the Supreme Court affirmed. View "Idaho v. Clinton" on Justia Law

Defendant-Respondent-Appellant Stephen Adams appealed a district court judgment that upheld a magistrate judge's order that dismissed his motions to modify child custody and child support. Defendant's had been held in contempt for failing to make one child support payment. He was unable to purge the contempt by paying all delinquent child support payments for reasons he said were beyond his control. A court can impose a criminal contempt sanction in nonsummary contempt proceedings only if the contemnor has been afforded the federal constitutional rights applicable to criminal contempt proceedings. The magistrate held that it could refuse to hear the Father's motions because he was unable to purge the contempt and could not prove that his inability was due to circumstances beyond his control. The district court held that refusal to hear the Father's motions was a permissible criminal contempt sanction. Idaho Code section 7-610 does not authorize denial of access to the courts as a criminal contempt sanction. Therefore, the district court erred in affirming the magistrate's order on the ground that it was a permissible criminal contempt sanction. The Supreme Court held that the district court erred in affirming the magistrate court's order. In addition, the Supreme Court held that refusal to hear a motion and dismissal of a motion that the contemnor did not purge the contempt violates Article I, Section 18 of the state constitution. The district court was reversed and the case remanded. View "Slane v. Adams" on Justia Law

Defendant-Appellant Timothy Dunlap received the death penalty following his guilty plea to first-degree murder. He appealed the sentence, alleging multiple errors during trial, and that he received ineffective assistance of counsel. Although the Supreme Court found found error in the direct appeal from the sentencing proceedings, it held those errors, individually and cumulatively, were harmless. As to the appeal of the order summarily dismissing defendant's petition for post-conviction relief, the Court held that the district court erred in summarily dismissing defendant's claim of ineffective assistance of counsel regarding the investigation and presentation of mitigating evidence and the rebuttal of the State’s evidence in aggravation and defendant's "Brady/Napue" claim. Therefore, the Court vacated the district court’s judgment granting summary dismissal of defendant's petition for post-conviction relief and remanded the case for further proceedings. View "Idaho v. Dunlap" on Justia Law

Dale Shackelford appealed two consecutive fixed life sentences he received on resentencing for two first-degree murder convictions. He was initially sentenced to death for both murders but the death sentences were subsequently set aside. Shackelford contends that the district court committed error in resentencing him to the consecutive fixed life sentences. Upon review of the district court record, the Supreme Court concluded that the district court did not abuse its discretion nor violate Shackelford's Sixth Amendment right of confrontation. Accordingly, the Court affirmed the judgment of conviction sentencing Shackelford to two consecutive fixed life sentences. View "Idaho v. Shackelford" on Justia Law