Justia Idaho Supreme Court Opinion Summaries

Plaintiff-Counterdefendant-Appellant David Oakes, M.D. was employed as a cardiologist by Defendant-Counterclaimant-Respondent Boise Heart Clinic Physicians, PLLC (BHC) from January 2000 until the end of July 2008, when he left to pursue other employment opportunities. While employed by BHC, Plaintiff had an employment agreement that entitled him to half the adjusted gross charges he generated. Because of his complicated arrangements with other service providers, Plaintiff's final payment was not calculated until after his departure. After his employment ended, Plaintiff corresponded with BHC regarding his final payment. Plaintiff never received payment. Instead, he received a series of letters that detailed the evolving computation of his final payment. BHC's last letter to Plaintiff included a demand for repayment. Plaintiff then sued claiming that BHC still owed him money under the employment agreement. In rendering its verdict, the jury was given a choice between three special verdict forms that corresponded with the three possible verdicts: one finding that neither party is entitled to recover from the other; one that finding that BHC owed money to Plaintiff; and one finding that Plaintiff owed money to BHC. The jury returned with a verdict in favor of Plaintiff, and against BHC, that awarded Plaintiff $2,043.92. Ultimately the district court entered a final judgment that awarded Plaintiff $2,043.92 and declared that neither party was the prevailing party for purposes of costs and attorney fees. Plaintiff appealed the "prevailing party" decision to the Supreme Court. e sought. The district court entered a judgment conferring to Oakes the amount awarded by the jury, but found that neither party was the prevailing party for purposes of costs or attorney fees. Upon review, the Supreme Court held that the district court abused its discretion by not finding Plaintiff to be the prevailing party. The case was remanded for a determination of costs and fees. View "Oakes v. Boise Heart Clinic Physicians, PLLC" on Justia Law

In 2008, Defendant Abelardo Gomez was arrested and charged with one count of conspiracy to traffic in cocaine and eleven counts of trafficking in cocaine. In a plea agreement reached with the State, Defendant agreed to plead guilty to three counts in exchange for an eight year fixed sentence. At sentencing, the district court also imposed a twenty-five year indeterminate sentence and a restitution order totaling $129,534.97. Defendant argued that the imposed sentence was excessive, and that the restitution order is a violation of the plea agreement since it was not contemplated in the agreement. Upon review, the Supreme Court found that the trial court did not abuse its discretion in imposing Defendant's sentence and ordering restitution. Accordingly, the Court affirmed the district court's order. View "Idaho v. Gomez" on Justia Law

In 2004, Defendant Randy Koivu was charged with possessing methamphetamine. He was found guilty and the district court sentenced him to five years in the custody of the Idaho Board of Correction, with three years fixed and two years indeterminate. The court suspended that sentence and placed Defendant on probation for four years. The terms of probation included that Defendant pay a fine, court costs, public defender reimbursement, and restitution. Defendant later violated the terms of his probation, and the court revoked his probation and committed him to the custody of the Idaho Board of Correction. Defendant was released in 2009. A few months after his release, a deputy court clerk filed an affidavit stating Defendant failed to pay his fines and court costs. The court issued a warrant of attachment to have Defendant seized and brought before the court to show cause why he should not be punished for contempt for failing to pay his fines. No copy of the order was attached to the warrant of attachment, but bail was set and would be released when Defendant posted bail. In 2010, Defendant was pulled over for speeding, and law enforcement arrested him on an outstanding warrant. While searching Defendant at the jail, a baggie of methamphetamine was discovered near his feet. Defendant was ultimately charged again for possession of methamphetamine, and found as a "persistent violator." The prosecuting attorney moved to dismiss the warrant of attachment pursuant to which Defendant had been arrested. The district court dismissed the prosecution's motion for lack of jurisdiction on the 2009 warrant. The lack of jurisdiction was apparently based upon the fact that the district court had not sentenced Defendant to a fine and court costs, but had only ordered him to pay such sums as a condition of probation. Upon the revocation of his probation, Defendant was no longer required to pay them. As a result, the district court issued an order suppressing the methamphetamine. The State then timely appealed. The State asked the Supreme Court to overrule "Idaho v. Guzman," (842 P.2d 660 (1992)) to hold that the good-faith exception to the exclusionary rule applied to violations of Article I Section 17 of the state constitution. Because the State did not show any ground for doing so, the Court declined to overrule that case and affirmed the district court's order suppressing evidence obtained incident to the wrongly issued 2010 warrant. View "Idaho v. Koivu" on Justia Law

Defendant Filip Danney appealed a district court’s denial of his motion to suppress evidence of drugs obtained through the use of a drug dog during a traffic stop. On appeal, Defendant argued that the district court erred in determining that: (1) a proper foundation was laid for the admission of Global Positioning System (GPS) data used in his prosecution; (2) reasonable suspicion existed to justify the warrantless extension of his traffic stop; and (3) the government’s placement of a GPS device constituted an impermissible warrantless search. Because the Supreme Court agreed that the officer had a reasonable articulable suspicion of possible criminal activity justifying the limited detention of Defendant for purposes of a drug dog search, the Court affirmed the district court's decision. View "Idaho v. Danney" on Justia Law

Claimant Brooke Stark worked for Assisted Living Concepts, Inc. from 2008 to 2010 as a "residence director" of one of Assisted Living's facilities. Claimant was called into the sales director's office one day, and the two talked about a rumor that one of Assisted Living's other facilities was imminently closing. Later that evening, Assisted Living's divisional director of human resources called Claimant to ask where Claimant heard of the closing rumor. Claimant did not disclose her source. Five minutes following that call, Assisted Living's chief executive officer called Claimant (with the director of HR on the call) to ask about the rumor. Claimant said she talked to a number of people, but that she did not want to share the information. The CEO emphasized the importance of knowing who started the rumor so that the company could reassure those involved that the facility in question would not close. Still declining to reveal her source, the CEO suspended Claimant. The human resources director, after a little investigation, found that Claimant violated company policy by refusing a direct order from her supervisor. Claimant was then terminated in the fall of 2010. The issue before the Supreme Court involved whether Claimant's refusal to respond to the CEO's question. The Industrial Commission held that Claimant's refusal to obey the direct order did not constitute misconduct under the Employment Security Law. The Supreme Court held as a matter of law, Claimant's conduct was indeed misconduct under the Employment Security Law, and reversed the Industrial Commission. View "Assisted Living Concepts , Inc. v. Idaho Dept of Labor" on Justia Law

Defendants-Appellants Stanley and Catherine Jensen, as trustees of the Stanley and Catherine Jensen Family Living Trust, appealed the district court's decision that granted Plaintiff-Respondent Rocky Mountain Power's motion for summary judgment. Defendants are record owners of a cattle ranch that lies within a corridor established by the Utility for a 345 kilovolt transmission line. The Utility sought a perpetual easement and a right of way for the Utility and its successors and assigns to locate, construct, reconstruct, operate, and maintain a 150 foot wide high-voltage overhead power line utility corridor through the eastern part of Defendants' property. In 2008, Defendants entered into an Occupancy Agreement with the Utility, waiving all defenses to the Utility's acquisition of the easement, except the claim of just compensation. Upon execution of the Agreement, Defendants were paid $215,630 which would be deducted from any final determination of just compensation for the easement. Under the terms of the Occupancy Agreement, if just compensation was determined to be less than $215,630, Defendants were not required to return the difference. The parties were unable to reach an agreement for just compensation within a specified time, so the Utility filed its Complaint in early 2009, seeking a decree of condemnation, an award of easement, and specific performance of the Occupancy Agreement. The Utility filed a motion for summary judgment, contending that Defendants did not identify any expert witnesses or laid a proper foundation for any probative evidence of just compensation. Upon review, the Supreme Court found that Defendants failed to establish a genuine issue of material fact to establish the fair market value of their property. Accordingly, the Court affirmed the district court's judgment. View "Rocky Mountain Power v. Jensen" on Justia Law

Defendant-Appellant Robert Gurney pled guilty to possession of marijuana with intent to deliver. He then successfully completed drug court. Upon completion, he requested and received a dismissal of the charge. He also requested that the record of his criminal case be sealed, pursuant to I.C.A.R 32(i), on the basis of economic hardship. The district court denied this second request. It subsequently denied Defendant's request to change the caption of this case on appeal to an abbreviated version of his name which would conceal his identity. Defendant appealed both decisions. Upon review, the Supreme Court concluded the district court did not err by denying Defendant's motion to seal his records or amend the caption of his case: "[a]s the district court recognized that the decision was committed to its discretion, recognized and applied the applicable legal standard, and did so through the exercise of reason, [the Court was] unable to conclude that the decision was an abuse of discretion." View "Idaho v. Gurney" on Justia Law

Defendant-Appellant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. Defendant raised several issues on appeal pertaining to the sufficiency of the evidence presented against him at trial, and procedural errors that prejudicially lead to his conviction. Taking each of Defendant's issues raised on appeal, and after a review of the trial record and applicable law, the Supreme Court found that the jury was presented with sufficient evidence from which it could reasonably find that Defendant was guilty of first-degree murder, and that the trial court committed no fundamental errors that adversely impacted Defendant's trial. Accordingly, the Court affirmed Defendant's convictions and sentences. View "Idaho v. Adamcik " on Justia Law

The constitutionality of "Plan L 87," a legislative redistricting plan adopted by the Commission on Redistricting for reapportionment, was challenged and brought before the Supreme Court. Upon review, the Court found that the Plan complied with the strictures of the Fourteenth Amendment's Equal Protection Clause of the federal constitution. However, the Plan did not comply with Article III, section 5 of the Idaho Constitution in that it did not "divide counties only to the extent that [they] must be divided to comply with the Federal Constitution." Furthermore, the Plan did not "avoid dividing counties whenever possible in violation of Idaho Code section 72-1506(5)." The Court did not order the Commission to adopt any one redistricting plan: "The commission certainly has the discretion to reject plans that have been submitted and draw boundaries in another manner that complies with both Constitutions." The Court directed the commission to reconvene and adopt a revised plan. View "Twin Falls County v. Idaho Commission on Redistricting" on Justia Law

In 2003, Defendant Lonnie Forbes pled guilty to attempted lewd conduct with a minor child under sixteen years of age. The district court withheld judgment three months later and placed Defendant on probation for seven years. As a result of his plea, Defendant was required to register as a sex offender. When Defendant committed the crime, Idaho law permitted him to request to withdraw his guilty plea and have the case dismissed. The district court was given discretion to grant Defendant's request so long as Defendant complied with the terms of his probation. Three years later, the law was amended. Three years after that, Defendant's probation was amended to unsupervised probation, with all other terms of probation still in effect. In 2010 when Defendant met the requirements of his withheld judgment, he moved to set aside his guilty plea and for a restoration of his civil rights. The State opposed Defendant's motion to dismiss, but the district court granted Defendant's request. The State appealed, arguing that the change in the law governing Defendant's sentence and probation barred Defendant's ability to have his case dismissed. Upon review, the Supreme Court held that the district court erred by retroactively applying the amended law to Defendant's case. The district court's decision was vacated and the case remanded for further proceedings. View "Idaho v. Forbes " on Justia Law