Justia Idaho Supreme Court Opinion Summaries

This case arose out of an appeal of the district court's refusal to grant a dismissal following an evidentiary hearing in 2011. In 1988, Defendant Philip Dieter entered a plea agreement with the State in which he agreed to plead guilty to lewd conduct in exchange for the State's dismissal of two related charges. Subsequently, the court entered an Order of Withheld Judgment and Order of Probation. Following an amended order that enlarged the terms of probation, the district court dissolved and terminated probation in 1992. However, it did not dismiss the case. Defendant argued that the district court should have been required to dismiss the case because the initial order contained a clause that stated the case would be dismissed if Defendant fully complied with his probation terms. He also argued that the district court had no authority to deny the dismissal. Upon review of the district court's decision, the Supreme Court affirmed. View "Idaho v. Dieter" on Justia Law

During a traffic stop, police officers searched Defendant-Appellant Steven Clay Anderson's vehicle based on a drug dog's alert on the exterior of the vehicle, as well as other suspicious circumstances. The district court denied Defendant's motion to suppress evidence found during the search, holding that probable cause did not dissipate when the same dog failed to alert a second time when placed inside the vehicle. On appeal, the Court of Appeals affirmed. Upon review, the Supreme Court affirmed: "in the absence of something more to neutralize probable cause, the initial alert, coupled with the surrounding suspicious circumstances, entitled the officers in this case to perform a thorough search of Anderson's vehicle, including the manual search performed following the failed alert. Thus, the district court correctly denied Anderson's motion to suppress the evidence found in that search." View "Idaho v. Anderson" on Justia Law

The appellant had filed a petition for reconsideration of an administrative order issued by the Idaho Department of Water Resources, and, when the Department failed to decide the merits of the petition within twenty-one days, the appellant filed a petition for judicial review of the Department’s order, contending that the petition for reconsideration was deemed denied pursuant to Idaho Code section 67-5246(4). The Department later decided the petition for reconsideration and issued an amended order. The district court held that section 67-5246(4) did not require the Department decide the merits of the petition for reconsideration within twenty-one days; it only had to agree to consider the petition within that time frame. The court therefore dismissed appellant’s petition for judicial review on the ground that the order it sought to have reviewed had been superseded by the amended order. The Supreme Court vacated the dismissal because the petition for reconsideration was deemed denied by section 67-5246(4) when the Department failed to decide it within twenty-one days, and the amended order was therefore a nullity because the Department did not have jurisdiction to issue it. View "A&B Irrigation District v. Idaho Dept of Water Resources" on Justia Law

This case concerned the Director (Director) of the Idaho Department of Water Resources' application of the Rules for Conjunctive Management of Surface and Ground Water Resources (CM Rules) in response to a ground water to ground water delivery call filed by the A&B Irrigation District (A&B). The Director’s Final Order found that A&B was not materially injured and was affirmed by the district court on nearly all points. A&B appealed to the Supreme Court, contending that the Director and the district court erred in their analyses. The City of Pocatello and the Idaho Ground Water Appropriators, Inc. cross-appealed alleging that the district court erred by requiring that the Director's finding of no material injury must be supported by clear and convincing evidence, rather than a preponderance of the evidence. Upon review of the matter, the Supreme Court affirmed the decision of the district court. View "A & B Irrigation v. Idaho Dept of Water Resources" on Justia Law

Two personal injury actions and one wrongful death action arising out of an automobile accident were consolidated on appeal before the Supreme Court. In 2007, Paul -Smith's vehicle collided with a semi-tractor trailer driven by Robert Petrovich. Nicole Plouffe and Tiffany Ann Marie Fragnella were both passengers in Smith's vehicle. Plouffe was severely injured and Fragnella died as a result of her injuries. At the time of the accident, Petrovich was driving the semi-truck for Swift Transportation Co., Inc., and was training a Swift Transportation employee in driving skills. The Swift Transportation trainee, Thomas Thayer, was a passenger in the semi-truck at the time of the collision. Thayer was covered under Swift Transportation's workers' compensation insurance. Smith and his passengers' Amended Complaint alleged that Petrovich was negligently driving the semi-truck. The district court granted summary judgment in favor of the Petrovich and Swift, finding that there was no evidence that the accident was caused by Petrovich. The district court also concluded that a third party claim for negligence against Petrovich was separately barred by the exclusive remedy rule under Idaho's Workers' Compensation statutes. Smith appealed to the Supreme Court arguing that the district court erred in granting summary judgment, that the court abused its discretion in denying the Motions for Reconsideration, and that the court erred in determining that the exclusive remedy rule barred the third-party claims against Petrovich. Upon review, the Supreme Court affirmed the district court's grant of summary judgment in favor of Petrovich, and found no error in the district court's decision. View "Fragnella v. Petrovich" on Justia Law

This case concerned the ownership status of Coolwater Ridge Road in Idaho County. The predecessors in interest of appellant Paddison Scenic Properties, Family Trust, L.C. granted rights of way to the United States for a road which became Coolwater Ridge Road. In the district court, Paddison sought a declaratory judgment that the rights of way did not constitute a public road or highway under Idaho law. That court held that the rights of way were public because the criteria for common law dedication were met. Upon review, the Idaho Supreme Court vacated the district court's judgment because it concluded this case was not ripe for adjudication. View "Paddison Scenic Properties Family Trust v. Idaho County" on Justia Law

The issue on appeal before the Supreme Court pertained to an order suppressing evidence. A law enforcement officer following two vehicles turned on the overhead lights of his patrol car in order to pull over the lead vehicle. Both vehicles pulled over, and the officer parked his car behind the lead vehicle and several car lengths in front of the rear vehicle. When the officer got out of his car, he walked back to the rear vehicle to tell the driver he was only stopping the lead vehicle. The district court held that by walking towards the rear vehicle, the officer seized its occupants without a reasonable, articulable suspicion that they had violated any law. The Supreme Court reversed: when approaching the rear vehicle, the trooper did not draw his gun or make any hand gestures indicating that the vehicle should not leave, nor did he even shine his flashlight at it. Considering the totality of the circumstances in this case, the trooper did not seize the rear vehicle by walking up to the driver's door. His actions certainly indicated that he wanted to talk to the driver, but the Supreme Court concluded that did not constitute a seizure. View "Idaho v. Ray" on Justia Law

This appeal was a consolidation of two actions relating to residential leases on State endowment lands. In one action, the Attorney General sought a declaratory ruling that I.C. 58-310A, which exempts so-called "cottage site" leases from conflict auctions, was unconstitutional in light of Article IX, section 8 of the Idaho Constitution. The district court determined that I.C. 58-310A was constitutional, and thus, dismissed the Attorney General's complaint. The Attorney General appealed that decision. In the other action, Gladys Babcock and several others who lease cottage sites on Payette Lake filed an action against the State Board of Land Commissioners and the Idaho Department of Lands Director. The Payette Lake Lessees alleged that the Board breached their lease agreements when it declined to renew the expiring leases for an additional ten years. The district court granted summary judgment to the Board, finding the Payette Lake Lessees had failed to exhaust their administrative remedies. The Payette Lake Lessees filed a cross-appeal challenging that decision. Upon review of the cases, the Supreme Court reversed the district court's ruling on the Attorney General's claim because I.C. 58-310A was unconstitutional. The Court vacated the district court's holding with respect to the Payette Lake Lessees' claim and remanded both cases for further proceedings. View "Wasden v. Board of Land Commissioners" on Justia Law

The issue on appeal before the Supreme Court was a challenge to the failure of a district court to give preclusive effect to a California federal district court judgment during a proceeding to grant recognition of a subsequent German judgment. Plaintiff Ron Markin executed a promissory note in 1988 agreeing to pay Defendant Thomas Grohmann $551,292.00 with interest at ten percent per annum. The loan was for a business transaction between the parties. In September 1997, Plaintiff sued Defendant in the United States District Court in the Central District of California in order to collect the promissory note. At that time, Defendant resided in Scottsdale, Arizona. The parties entered into a written settlement agreement to resolve the lawsuit. The agreement provided the principal and interest owing; that the lawsuit would be dismissed if that sum plus interest was paid according to the terms of the agreement; that the court would retain jurisdiction to enforce the agreement; that if the amount due under the agreement was not paid in full as provided in the agreement, Plaintiff could obtain a judgment as provided by California law; and that the agreement "shall be governed by and interpreted under the laws of the State of California." Defendant failed to pay according to the agreement, and Plaintiff obtained an ex parte judgment against Defendant. After learning that Defendant owned real property in Germany, Plaintiff commenced a civil action in Germany to enforce the California judgment. The German trial court dismissed the action on the ground that the judgment was not enforceable under German law. Plaintiff appealed and asserted that if the judgment was not enforceable, he could recover on the settlement agreement upon which that judgment was based. The appellate court agreed, and it issued an opinion ordering Defendant to pay Plaintiff. The court held that it could enter a judgment against Defendant based upon the settlement agreement because he had previously been a German citizen. Upon its review of matter, the Idaho Supreme Court concluded that the German judgment was a final judgment under German law. But because the German judgment did not recognize the effect of a final judgment under California law, it conflicted with the California judgment. The Idaho Court therefore reversed the judgment of the district court that recognized the German judgment. View "Markin v. Grohmann" on Justia Law

Plaintiffs Paul Trunell and Bill Lomu appealed a district court's ruling against them in their request for injunctive relief. Plaintiffs' complaint alleged the existence of a public road across Defendant Verna Fergel's property, and that she denied access to the road causing damage to Plaintiffs. The district court held that Defendant was a bona fide purchaser for value, and that she did not have actual or constructive notice of the public nature of the road when she purchased the property. Upon review of the trial court record, the Supreme Court found that the "bona fide purchaser for value" defense was not available to Defendant as it would have constituted an abandonment of the road in contravention to Idaho law. The Court therefore reversed the district court's holding and remanded the case for further proceedings. View "Trunnell v. Fergel" on Justia Law