Justia Idaho Supreme Court Opinion Summaries

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

Plaintiff-Appellant Victoria Johnson appealed the district court's grant of summary judgment in favor of North Idaho College (NIC) on her claim of discrimination under the Idaho Human Rights Act (IHRA). Plaintiff alleged one of her instructors sexually harassed her, and that NIC was vicariously liable for that harassment. The district court held that NIC's affirmative defense was factually support, and that she failed to establish a genuine issue of material fact. Upon review of the facts of this case, the Supreme Court concluded that the district court did not err in finding that no genuine issue of material fact existed in regard to Plaintiff's claims. Accordingly the Court affirmed the opinion of the district court. View "Johnson v. North Idaho College" on Justia Law

Petitioner Richard Leavitt petitioned the Supreme Court for a writ of mandamus to direct the Commission of Pardons and Parole (Commission) to schedule a full hearing on his petition for commutation and comply with its rules for such a hearing by publishing notice of the time and place of the hearing in a newspaper of general circulation at least once per week for four weeks prior to the hearing. After the Supreme Court affirmed the issuance of Petitioner's death warrant, the Commission denied Petitioner's request for a hearing. Petitioner asked the Supreme Court to set a date for a hearing wherein the Commission must show cause why a full hearing should not be conducted; if granted, the hearing would effectively stay his execution. Upon review, the Supreme Court concluded that the Commission was not required to grant Petitioner a full, open hearing regarding his commutation petition. Furthermore, Petitioner did not demonstrate that his request for the writ of mandamus or alternative writ should have issued. Accordingly, the Court denied Petitioner's requests. View "Leavitt v. Craven" on Justia Law

Appellant Richard Leavitt appealed his death warrant. He also appealed the district court's denial of his motion to quash the death warrant. In 1984, Appellant brutally attacked, sexually mutilated and murdered a 31-year-old woman in Blackfoot, in which a jury found him guilty of first-degree murder. In 1989, the Supreme Court affirmed his conviction, but reversed the death sentence because the trial court failed to weigh all the mitigating factors against the statutory aggravating factor that the murder was especially heinous, atrocious or cruel manifesting in exceptional depravity. On remand, the district court held another sentencing hearing and again sentenced Appellant to death. The warrant was issued in 1992, with a scheduled date of execution 23 days later. The United States Supreme Court granted Appellant's stay of execution. In 2000, Appellant was granted the writ of habeas corpus because of an improper jury instruction and ordered the State to retry Appellant. The State appealed, and the Ninth Circuit reversed the habeas order. The case was remanded to determine whether Appellant's resentencing hearing in 1989 violated his constitutional rights. In 2007 on remand, the district court again granted habeas relief. The State appealed in 2011, and the Ninth Circuit again reversed the habeas order. In 2012, Appellant filed a motion for relief from judgment; the Ninth Circuit issued a mandate automatically lifting any stay previously imposed by the habeas court. The habeas court denied Appellant's motion, and denied his request for a stay of execution. Appellant's appeal of that order was pending before the Ninth Circuit, but anticipating the issuance of a new death warrant, he filed notice of Demand for Opportunity to be Heard regarding the Issuance of the Death Warrant in Idaho district court. The court denied the motion because at that time, no stay of execution or death warrant was then pending before any court. Subsequently, the court signed Appellant's death warrant and scheduled his execution. Appellant raised multiple challenges to each procedural stage of his case, from sentencing, habeas relief, constitutional rights violations and the eventual signing of his death warrant. Taking all in turn, the Supreme Court found no errors arising from this case's journey to the Idaho Supreme Court. Accordingly the Court affirmed the district court and declined to stay Appellant's execution. View "Idaho v. Leavitt" on Justia Law

The issue on appeal in this case came from a decision of a district court which held that in a hearing regarding an administrative license suspension pursuant to Idaho Code section 18-8002A, the hearing officer must consider the margin of error of the breath testing machine when determining whether the test results support suspension. Facing a license suspension, Defendant Alma Elias-Cruz argued at trial that any suspension must be based upon her actual blood alcohol concentration rather than the alcohol concentration as shown by the test because, due to the test's margin of error, her actual blood alcohol content could have been below the statutory limit, and that the testing equipment had not been calibrated once a year as recommended by its manufacturer. The district court ruled sua sponte that her due process rights were violated by the hearing officer's rejection of the equipment's margin of error and that she had a statutory right to present such evidence. The court vacated the hearing officer's decision and ordered the matter remanded. The State then timely appealed. The Supreme Court reversed: "[u]nder Idaho Code section 18-8002A(1)(e), by definition the test results show the alcohol concentration. The issue is not the alcohol concentration in the blood. It is the alcohol concentration as shown by the test results. There is nothing to which to compare the test results. All that is required is that the test results show that the alcohol concentration was above the legal limit." The Supreme Court concluded the district court erred in its interpretation of that statute. View "Elias-Cruz v. Idaho Dept. of Trans." on Justia Law

The issue on appeal to the Supreme Court concerned Appellant Daniel Fuchs appeal of a district court's decision which found that the Director of the Idaho State Police Alcohol Beverage Control (ABC) had properly exercised his discretion when he ruled that neither party had been a prevailing party for the purposes of attorney fees. Fuchs was issued a Retail Alcohol Beverage License and subsequently opened Aubrey's House of Ale (Aubrey's) in Coeur d'Alene. The Alcohol Beverage Control Bureau Chief conducted an unannounced inspection of the premises. After this inspection, ABC filed a Complaint for Forfeiture or Revocation of Retail Alcohol Beverage License regarding Fuchs's license. Eventually, the parties filed cross motions for summary judgment in the action before an ABC hearing officer. After oral argument, the hearing officer granted summary judgment to Fuchs. On appeal to the Director of the ABC, the Director did not order Fuchs' license revoked because of confusion surrounding the proper interpretation of the applicable rule under which Fuchs was cited. The Director's Final Order addressed the hearing officer's erroneous application of quasi-estoppel and Fuchs' unsuccessful arguments regarding improper rulemaking and claim that the agency acted arbitrarily. The Director denied attorneys' fees to both parties, declaring neither was the prevailing party because neither acted without a reasonable basis in fact or law. Upon review, the Supreme Court agreed that Fuchs was not a prevailing party and affirmed the district court's decision to deny fees. View "Fuchs v. Idaho State Police" on Justia Law

This appeal arose from a condemnation action brought by the Idaho Transportation Board (ITB) against HI Boise, LLC. ITB sought to acquire a strip of land as part of a project to improve the I-84/Vista Avenue Interchange in Boise. ITB offered HI Boise the condemned property's appraised value of $38,177, but HI Boise filed a counterclaim for inverse condemnation, claiming damages of $7.5 million for additional lost rights of access and visibility. HI Boise appeals the district court's summary dismissal of those claims. Because the Supreme Court found that neither claim involved a compensable taking, the Supreme Court affirmed. View "Idaho Transportation Board v. HI Boise, LLC" on Justia Law

The issue before the Supreme Court in this case concerned the approval of a permit application for a Livestock Confinement Operation (LCO), also known as a Concentrated Animal Feeding Operation (CAFO), by the Jerome County Board of County Commissioners. The Board approved the application after a remand by the district court of the Board's decision previously denying the permit. Several individuals and organizations opposed to the LCO because of the potential harms to the neighboring farms and to the Minidoka National Historic Site petitioned the district court for review of the Board's decision. The district court affirmed the Board's approval of the permit, finding in the process that four of the organizations concerned with the effects on the Minidoka National Historic Site lacked standing. Several of the objecting parties appealed the district court's decision, asking the Supreme Court to find that these parties had standing to challenge the permit approval, that the Board's procedure for presenting evidence before the Board violated procedural due process rights, and that the Board failed to follow all of the county's relevant zoning ordinances when it approved the application. The issue central to the Court's opinion pertained to standing of all the appellant-organizations, the Board's procedure for presenting evidence throughout the LCO permit application process, the constitutionality of the "one mile rule" of Idaho Code section 67-6529, and the application of the Jerome County Zoning Ordinances. The Court concluded that the Board properly applied its zoning ordinance to the LCO permit application process, that I.C. 67-6529 was not unconstitutional, and that the public was afforded appropriate due process prior to, and during the LCO permit application hearing. View "Friends of Minidoka v. Jerome County" on Justia Law

After moving from the address that he reported to the Idaho State Police Sex Offender Registry pursuant to the sex offender registration requirements of I.C. 18-8309 (2001) and having been extradited from Belize, Defendant David Leroy Lee was convicted of Failure to Register as a Sex Offender in 2009. Defendant asserted on appeal that the plain language of I.C. 18-8309 did not require sex offenders to register or update their address information with either the Registry or the sheriff of the county where the offender was required to register after moving to another country. In the alternative, he contended that the State failed to provide evidence establishing beyond a reasonable doubt that he moved from his last known address to a definite new address or actual residence thereby triggering his duty to notify the Registry or the sheriff. Furthermore, Defendant claimed that I.C. 18-8309 was unconstitutionally vague and that his due process rights were violated. Upon review, the Supreme Court found that the evidence was not sufficient to prove beyond a reasonable doubt that Defendant changed his address or actual residence. The Court therefore vacated the district court's Amended Judgment of Conviction, and remanded this case with instructions for the entry of a judgment of acquittal. View "Idaho v. Lee" on Justia Law