Justia Idaho Supreme Court Opinion Summaries

At issue before the Supreme Court in this case was appeal and cross-appeal of summary judgments dismissing claims against Defendants Ada County, Deputy Jeremy Wroblewski, Kate Pape, and James Johnson in a 42 U.S.C. 1983 civil rights action brought by Rita Hoagland on behalf of herself and the estate of her deceased son, Bradley Munroe ("Munroe"), claiming a violation of a Fourteenth Amendment right to medical care and safety while Munroe was detained at Ada County Jail where he committed suicide. Munroe had a history of incarceration at Ada County Jail ("ACJ"). During the evening of September 28, 2008, Munroe was arrested and charged with the armed robbery of a convenience store. Munroe was intoxicated and uncooperative. During booking, Munroe was screaming and being rowdy. Munroe took a string and wrapped it around his neck. Because of his bizarre behavior throughout the night, Munroe was placed in a holding cell for observation until he was sober. The next morning booking continued. At that time, Munroe requested protective custody. Munroe was placed in a cell by himself and a well-being check was scheduled to occur every thirty minutes. Later that evening during a well-being check, the performing deputy found Munroe hanging from his top bunk by a bed sheet. Munroe was pronounced dead later that evening. Among the issues on appeal were: whether the decedent's estate could assert a 42 U.S.C 1983 action for alleged violations of the decedent's constitutional rights; whether the parent had standing to assert a 42 U.S.C. 1983 action for the death of her adult child while incarcerated; and whether the district court erred in awarding costs to Defendants. Upon review, the Supreme Court concluded that the district court: (1) was affirmed in dismissing Hoagland's 1983 claim on behalf of Munroe's estate; (2) was reversed in finding that Hoagland had a 1983 cause of action for violations of her own constitutional rights; (3) was partially affirmed in its award of costs as a matter of right; (4) was reversed in its award of discretionary costs; and (5) was affirmed in denying attorney fees. The case was remanded for the reconsideration and entry of express findings regarding the district court's award of discretionary costs. View "Hoagland v. Ada County" on Justia Law

In 2011, Gordon Ravenscroft filed a Petition for Judicial Review against Boise County, its Board of Commissioners, and other individual defendants. The petition sought review of the Board's final decision terminating Ravenscroft's employment. The petition claimed Ravenscroft was denied his constitutional right to due process, the board acted outside the bounds of its authority, and his firing was arbitrary, capricious, and an abuse of discretion. In response, the Board filed a motion to dismiss arguing that the district court was without jurisdiction to hear an appeal of a county personnel determination. The district court determined that it had jurisdiction over the Board's decision to terminate Ravenscroft because the decision was an "action" under I.C. 31-1506. The Board then sought permission to appeal this decision, which the district court granted. The question in this case is whether the Board's decision to terminate Ravenscroft is subject to the judicial review provisions of the Idaho Administrative Procedure Act [IAPA]. The IAPA and its judicial review provisions do not apply to the actions of local governing bodies, unless expressly authorized by statute. The Supreme Court concluded that the Board's decision to terminate Ravenscroft was an "Act" under I.C. 31-1506, and that his at-will status did not change the scope of Ravenscroft's claim. "If the employment is at will, judicial review will not enable the court to change it to employment terminable only for cause." The Court affirmed the district court's determination that the Board's decision to terminate Ravenscroft was an action under 31-1506. View "Ravenscroft v. Boise County" on Justia Law

Petitioner Peter Kaseburg was a littoral owner on Lake Pend Oreille who held an encroachment permit for a series of decaying wooden pilings that were driven into the lakebed in the 1930s. With the exception of a single piling that a neighboring marina uses to anchor one of its docks, the pilings never had any known navigational purpose. Petitioner applied to the Idaho Department of Lands (IDL) for a permit to replace ten of the wooden pilings with steel pilings, but failed to specify any navigational purpose for this proposal. The IDL considered the application a request for a nonnavigational encroachment permit and denied it after receiving several objections. While a final decision was still pending on the first permit application, Petitioner filed a second application for a permit to install a mobile dock system and mooring buoy. The IDL considered the second application a request for a permit for a navigational encroachment extending beyond the line of navigability. Again, the IDL received many objections and denied the application. Petitioner then sought judicial review, which reversed the IDL. The court held that all pilings were navigational encroachments as a matter of law, regardless of whether they have ever been used to aid navigation. The district court set aside both denials. The IDL appealed to the Supreme Court. Upon review, the Supreme Court reversed the district court with respect to the first application, but affirmed the district court with respect to the second. View "Idaho Bd of Land Comm v. Kaseburg" on Justia Law

In 2006, during the pendency of divorce proceedings, Charles Earl Guess, his wife, and their respective attorneys agreed that Ms. Guess and her attorney would meet Mr. Guess at the parties’ residence so that they could walk through the house and look in a vault in the house with Mr. Guess present. When Ms. Guess and her attorney arrived at the house, they walked with Mr. Guess into the basement where the vault was located. Mr. Guess allowed his wife and her attorney to walk into the vault first, and then he pulled out a semiautomatic pistol, pointed it at them, and stated that he was going to kill them. While holding the pistol in his right hand, he struck Ms. Guess twice in the face with his left fist. She and her attorney were ultimately able to talk Mr. Guess into putting the gun down. After Ms. Guess and her attorney were able to leave the house, they drove to seek medical care for her and to contact the police. The State charged Mr. Guess with two counts of felony aggravated assault, and one count of misdemeanor battery. Ultimately, he and the State entered into a written plea agreement. The State agreed to file an amended information charging him with one count of aggravated assault alleged to have been committed against both victims, to which he would plead guilty. The State then recommended that he be sentenced to a withheld judgment and be placed on probation for no more than five years, and he could withdraw his guilty plea if the district court was unwilling to impose a sentence consistent with that recommendation. Mr. Guess pled guilty to the charge, and the court imposed a sentence consistent with the written plea agreement, with the period of probation being five years. Mr. Guess appealed the sentence. Finding no abuse of the court's discretion, the Supreme Court affirmed. View "Idaho v. Guess" on Justia Law

This was an action brought by the grantor of a deed of trust to stop nonjudicial foreclosure proceedings based upon the contention that MERS, the Mortgage Electronic Registration Systems, which was the named beneficiary as nominee for the lender, could not legally act as the beneficiary. The defendants moved to dismiss this action on the ground that the complaint did not state a claim upon which relief could be granted. The district court agreed and entered judgment in favor of the defendants. Upon review, the Supreme Court affirmed the district court's judgment. View "Edwards v. MERS" on Justia Law

In 2011, Administrative District Judge Nye issued an Administrative Order Declaring Petitioner Holli Telford a Vexatious Litigant. At the time the pre-filing order was issued, there were no proceedings before Judge Nye to which Telford was a party. Judge Nye issued the pre-filing order after receiving requests from several district court and magistrate judges. The pre-filing order declared Telford a vexatious litigant on the basis that she "has previously been declared to be a vexatious litigant by any federal court of record in any action or proceeding." Telford had been declared vexatious by Utah, Texas, the Federal Ninth Circuit Court of Appeals, the Federal District Court of Idaho, the Federal District Court of Montana, and the United States Supreme Court. The pre-filing order also found Telford to be a vexatious litigant on the additional basis that she has commenced in Idaho three or more pro se litigations that were determined adversely to her in the past seven years. Telford was then served the pre-filing order. On appeal, Telford challenged the order deeming her a vexatious litigant, including attacking the merits of cases underlying the declarations of the other jurisdictions. Upon review, the Idaho Supreme Court found no abuse of discretion, and affirmed Judge Nye's pre-filing order. View "Telford v. Nye" on Justia Law

In 2007, Employers Mutual Casualty Company (EMC) brought a declaratory judgment action against the Donnellys and Rimar Construction, Inc. (RMI) to establish that under its policy of insurance with RCI, EMC had no duty or responsibility to pay damages claimed by the Donnellys in litigation between the Donnellys and RCI. The declaratory judgment action was stayed until a verdict was reached in the underlying action. In the underlying action, the Donnellys were awarded damages, costs and attorney fees against RCI. Subsequently the district court entered summary judgment in the declaratory action, finding that there was no insurance coverage for the damages the Donnellys incurred, but that there was coverage for costs and attorney fees. On appeal, EMC argued that the district court erred in its determination that it had a duty to pay attorney fees and costs when there were no damages awarded to the plaintiff subject to the policy coverage. The Donnellys cross appealed, arguing the district court erred in its conclusion that EMC did not have a duty to cover the damages in this case, and that the Donnellys were entitled to attorney fees. Upon review, the Supreme Court affirmed the district court's decision. View "Employers Mutual Casualty Co v. Donnelly" on Justia Law

The issue before the Supreme Court in this permissive interlocutory appeal was a district court's determination that the law of the case doctrine prohibited it from making a retroactive determination of Defendant-Respondent Faron Hawkins' mental competency when he stood trial in 2008. A jury convicted defendant of two counts of robbery. He appealed his conviction, and the court of appeals vacated the decision and remanded the matter for a new trial. The appellate court determined that the district court erred by not having defendant undergo a mental health evaluation during his jury trial to determine whether or not he was competent to proceed. Based on the totality of the evidence presented to it, "including admitted exhibits and testimony presented during the competency hearing," the district court found that Hawkins was both presently competent to stand trial and had been competent to stand trial in January 2008. However, the court found that the law of the case required it to retry the case. The Supreme Court held that the language in the trial court record regarding a retroactive competency determination and the State being free to retry Hawkins if he was found presently competent, was not the law of the case. Because there was no legal analysis on the subject of retroactive competency determinations and no factual discussion from the Court of Appeals as to why one would not be possible in this case, the Supreme Court read that court's conclusory statement as an acknowledgement that it had no record on which to base a retroactive competency determination. Therefore the Court reversed the district court and remanded the case for further proceedings. View "Idaho v. Hawkins" on Justia Law

Plaintiff-Appellant Larry Hansen was involved in an automobile accident with Defendant-Respondent Matthew Roberts. At trial, Plaintiff sought to recover damages for his injuries and Defendant sought to recover property damage for his vehicle. The jury found Plaintiff to be 90% at fault and awarded Defendant damages for his vehicle. Plaintiff appealed the district court's decision to allow Defendant's experts, an accident reconstructionist and a biomechanical engineer, to testify. Plaintiff also appealed the district court's ruling that he waived his objections to Defendant's deposition testimony. Finally, Plaintiff appealed the district court's decision to grant Defendant's motion in limine so far as it limited him from asking whether prospective jurors or one of their family members were or had ever been employed by an insurance carrier. Finding no abuse of the district court's discretion, the Supreme Court affirmed. View "Hansen v. Roberts" on Justia Law

The issue before the Supreme Court in this case concerned the grant of summary judgment dismissing an action to enforce an oral agreement to guaranty the debt of another on the ground that the agreement was barred by the statute of frauds. Sunshine Secretarial Services subleased office space from Accelerated Paving, Inc., and at times provided it with secretarial services. Accelerated Paving owed Plaintiff-Appellant Mickelsen Construction, Inc. money ($34,980.00) for providing asphalt to an Accelerated jobsite. Mickelsen threatened to file a materialmen’s lien against the real property on which the work was being done, and Accelerated's vice president asked that it not do so because that would delay the receipt of payment for the construction job. The vice president offered to pay the debt with an American Express credit card, but Mickelsen responded that it did not accept American Express credit cards. There was disagreement as to what happened next: Accelerate's vice president said there was not enough credit on the card to fund the payment, but when Accelerated received payment for the project it would pay down the balance so that there was enough credit to pay Mickelsen with the card. Mickelsen agreed not to file the lien if Accelerated could find someone to guaranty the payment by the credit card. Defendant-Respondent Lesa Horrocks of Sunshine agreed to do so and gave Mickelsen a check in the amount owed, drawn on Sunshine's account. Sunshine had a credit card machine that was capable of transacting with several credit cards including American Express credit cards. They told her that American Express had approved the transaction and asked her to use Sunshine credit card machine to run the transaction. It appeared to her that the transaction had been approved by American Express. issued the check. Several days later, Accelerated informed her that American Express had not approved the transaction. Accelerated then filed for bankruptcy. Mickelsen then sued Ms. Horrocks and Sunshine alleging that they had agreed to guaranty the credit card payment and so issued the check. The Defendants filed a motion for summary judgment, arguing that the alleged guaranty was barred by the statute of limitations in Idaho Code section 9-505. In response, Mickelsen argued that the check was a sufficient writing under the statute of frauds and, if not, that the transaction was governed by Idaho Code section 9-506 and therefore exempt from the statute of frauds. The district court held that the check was an insufficient writing and that section 9-506 did not apply because the Defendants did not receive any direct benefit. The court granted the motion for summary judgment and entered a judgment dismissing this action. Mickelsen then appealed. Finding no error with the district court's decision, the Supreme Court affirmed. View "Mickelsen Const v. Horrocks" on Justia Law