Justia Idaho Supreme Court Opinion Summaries

Defendant-Appellant Russell G. Jones appealed his conviction by jury on two counts of rape. The case was initially heard by the Idaho Court of Appeals, which affirmed on one count and reversed on the second. Defendant sought review, which the Supreme Court granted in order to consider the force and resistance necessary with respect to a charge of forcible rape. Given the weight and quantity of the unrefuted evidence across the board, versus the one statement regarding Defendant and the victim, the Court concluded that the district court erred in admitting certain statements made between Defendant and the victim, and that the admission of that statement was harmless. There was insufficient evidence on the element of resistance to support the conviction of forcible rape on Count II so the Court did not consider the issue of force. The conviction on Count II was accordingly reversed. View "Idaho v. Jones" on Justia Law

Subdivision developers Buckskin Properties, Inc. and Timberline Development, LLC (collectively Buckskin) brought suit against Valley County seeking recovery of monies paid to the County for road development, and declaratory relief from payment of any further monies. The district court granted summary judgment to the County and Buckskin appealed. Upon review, the Supreme Court concluded that a governing board may lawfully make a voluntary agreement with a land developer for the funding and construction of new infrastructure. Accordingly, the Court affirmed the grant of summary judgment to the County. View "Buckskin Prop v. Valley County" on Justia Law

In 2008, the legislature enacted legislation to establish the Idaho Education Network (IEN), which was to be a high-bandwidth telecommunications distribution system for distance learning in every public school in the state. Syringa Networks, LLC (Syringa), an Idaho telecommunications company, entered into a “teaming agreement” with ENA Services, LLC (ENA). Pursuant to their agreement, ENA submitted a proposal in response to a request-for-proposals (RFP) with the Department of Administration, although the cover letter stated that both ENA and Syringa were responding jointly to the proposal. Qwest Communications Company, LLC, and Verizon Business Network Services, Inc., also submitted responsive proposals. The proposals were then scored based upon specific criteria; the ENA and Qwest proposals received the highest scores. The Department issued a letter of intent to award contracts to Qwest and ENA. One month later, it issued amendments to the two purchase orders to alter the scope of work that each would perform. Qwest became "the general contractor for all IEN technical network services" (providing the “backbone”) and ENA became "the Service Provider." The effect of these amendments was to make Qwest the exclusive provider of the backbone, which was what Syringa intended to provide as a subcontractor of ENA. Syringa filed this lawsuit against the Department, its director, the chief technology officer, ENA and Qwest. The district court ultimately dismissed Syringa’s lawsuit against all of the Defendants on their respective motions for summary judgment. Syringa then appealed the grants of summary judgment, and the State Defendants cross-appealed the refusal to award them attorney fees. Upon review, the Supreme Court affirmed the judgment dismissing all counts of the complaint except count three seeking to set aside the State's contract with Qwest on the ground that it was awarded in violation of the applicable statutes. Furthermore, the Court reversed Qwest’s award of attorney fees against Syringa. We remand to the trial court the determination of whether any of the State Defendants were entitled to an award of attorney fees against Syringa for proceedings in the district court. The Court awarded costs and attorney fees on appeal to ENA. Because the State Defendants and Syringa both prevailed only in part on appeal, the Court did not award them either costs or attorney fees on appeal. View "Syringa Networks v. Idaho Dept of Admin" on Justia Law

Petitioner-Appellant Zane Jack Fields was incarcerated for the 1988 first degree murder of Mary Katherine Vanderford. The district court dismissed his petition for post-conviction relief in 2010, the fifth successive petition for post-conviction relief he filed. In the latest petition, Petitioner argued that the act of destroying an orange camouflage coat (introduced into evidence as a defense exhibit and used by eyewitnesses to identify him) was new evidence that established his innocence. The State moved to dismiss on grounds that Petitioner's newly discovered evidence claims were time-barred by statute, and the district court granted the motion. Upon review, the Supreme Court concluded that the district court was correct in finding Petitioner's petition was untimely filed, and affirmed. View "Fields v. Idaho" on Justia Law

This case arose from a district court's review on appeal of a magistrate court's decision regarding the civil forfeiture of a motorcycle and other items that belong to Christopher Rubey. In 2009, Rubey was arrested and charged with possession of methamphetamine with intent to deliver. Subsequently, the Ada County Prosecutor's Office (State) brought an action under I.C. 37-2744 for civil forfeiture of the motorcycle and related items used in the alleged crime. The magistrate court granted summary judgment to the State, and the district court reversed and remanded that decision. The State appealed to the Supreme Court, arguing that the district court erred in its decision and that the legislative intent behind I.C. 37-2744(a)(4) supports civil forfeiture for either the transportation or trafficking of drugs. Upon review, the Supreme Court agreed and affirmed the district court's decision. View "Ada Co Prosecuting Atty v. 2007 Legendary Motorcycle" on Justia Law

Defendant-Appellant Robert Barton, Jr. was found guilty by jury of solicitation of perjury. Defendant, the victim of aggravated battery, was charged with solicitation and conspiracy to commit perjury in connection to his testimony in the battery case. On appeal, Defendant argued that the jury should have been instructed on his defense of entrapment, and that such a defense was consistent with his plea of innocence. The State disagreed, arguing that no reasonable view of the evidence would support an instruction for entrapment and that such a defense is incompatible with his plea of innocence. Upon review, the Supreme Court found that the district court did not err when it refused to instruct the jury on the affirmative defense of entrapment, and affirmed the decision. View "Idaho v. Barton, Jr." on Justia Law

The issue before the Supreme Court on appeal in this case related to attorney fees incurred in litigation arising from a construction contract for a custom cabin in Island Park, Idaho. There were two issues: (1) whether the district court erred in holding that the Maglebys were entitled to recover only $2,500 from defaulting parties by operation of I.R.C.P. 54(e)(4); and (2) whether the district court erred in its decision regarding the Maglebys' entitlement to post-judgment attorney fees. Upon review, the Supreme Court concluded that I.R.C.P. 54(e)(4) did not limit the Maglebys' fees to the $2,500 pled in their complaint even though defendants did not contest them. The Court vacated the judgments of the district court as they related to attorney fees awards in light of I.C. sec. 12-120(5) and "ITP" and "Jenks." The case was remanded for further proceedings. View "Magleby v. Garn" on Justia Law

Petitioner-Appellant Randall Bottum appealed a district court order which held that a 2009 amendment to the sex offender registration law applied to him. Prior to the amendment, Petitioner could have petitioned the court to be exempted, but the amendment foreclosed that opportunity. Upon review of the district court order, the Supreme Court found that the 2009 amendment applied to Petitioner and affirmed the district court order. View "Bottum v. Idaho State Police" on Justia Law

Pro se plaintiff Martin Bettwieser brought a breach of contract action against the New York Irrigation District and its directors (collectively, the District). Bettwieser alleged that the District breached an oral contract by not timely providing him with a legal opinion regarding whether he could be excluded from the irrigation district without paying statutory exclusion and filing fees. Following a bench trial, the district court issued findings of fact and conclusions of law, ruling that Bettwieser had failed to demonstrate that he was entitled to relief. Bettwieser appealed, alleging the district court made errors of fact and law during the trial and in its decisions regarding Bettwieser's pre- and post-trial motions. As a preliminary matter, the Supreme Court noted that Bettwieser's briefing was, "at best, difficult to follow. In some cases, it is unclear what issue Bettwieser is attempting to raise. And, even where an issue is identifiable, argument, authority, and legal reasoning are often absent." The Court concluded that the district court's findings of fact and conclusions of law were supported by substantial competent evidence. Bettwieser failed to satisfy the requirements for certification of a class action. The district court was not obligated to consider claims not raised by the pleadings. The district court did not abuse its discretion in denying Bettwieser's motion to disqualify counsel. Bettwieser was not entitled to declaratory judgment because he failed to demonstrate the existence of an actual or justiciable controversy. View "Bettwieser v. New York Irrigation Dist." on Justia Law

In 2006, Woodrow John Grant pleaded guilty to aggravated battery; he successfully completed a period of retained jurisdiction and was placed on probation. In 2009, Grant was charged with possession of methamphetamine, domestic battery, aggravated assault, and unlawful possession of a firearm. Grant's appointed counsel moved to withdraw, stating that Grant had reneged on an agreed-upon plea bargain and that communications between them had broken down. The district court denied the motion. Later, Grant pled guilty to possession of a controlled substance and domestic battery, and admitted to violating the terms of his probation. The district court considered a letter and live testimony from the victim of Grant's domestic battery, in which the victim expressed her opinions on Grant's crime, character, and the sentence that would be proper for him. Thereafter, the district court sentenced Grant to five years fixed and five years indeterminate for domestic battery, to be served concurrently with a sentence of two years fixed and three years indeterminate for possession of methamphetamine. The district court revoked Grant's probation and executed his previously suspended sentence of four years fixed and six years indeterminate. The two new sentences were to be served consecutively to the reinstated 2006 sentence. Grant requested leniency in three I.C.R. 35 motions, which the district court denied. Grant appealed, arguing that the district court erred by refusing to allow his counsel to withdraw, by considering the victim's impact statements in their entirety, and by refusing his requests for leniency. Finding no error, the Supreme Court affirmed the district court in all respects. View "Idaho v. Grant" on Justia Law