Justia Idaho Supreme Court Opinion Summaries

Crystal Lorene Limary and Shaun Patrick McLean were married in 2015 and had one child together. They moved into a house purchased by Shaun's parents in 2016, making monthly payments to them until 2019 when Shaun took out a mortgage to buy the house, using a $70,000 gift of equity from his parents as a down payment. Crystal filed for divorce, and the couple disagreed on the classification of the house, the $70,000 gift, a camper trailer, and the parenting schedule for their daughter.The magistrate court held a four-day trial, during which it extensively questioned the parties and witnesses. The court determined that the house and camper trailer were community property and that the $70,000 was a gift to both Crystal and Shaun. Shaun appealed, arguing that the magistrate court's conduct at trial was inappropriate and biased. The district court agreed, finding that the magistrate court's active participation obscured the reliability of its decision. The district court vacated the judgment and remanded the case with instructions to reassign it to a different judge.The Supreme Court of Idaho reviewed the district court's decision and affirmed it. The court held that the magistrate court abused its discretion by extensively questioning the parties and witnesses, which affected Shaun's right to a fair trial. The court concluded that the district court did not err in vacating the judgment and remanding the case for a new trial with a different magistrate judge. Neither party was awarded attorney fees on appeal, but costs were awarded to Shaun as the prevailing party. View "Limary v. McLean" on Justia Law

This case involves the termination of parental rights and an adoption proceeding. Jane Doe 1 ("Mother") and John Doe ("Father") had a child out of wedlock. Approximately eight months after the child's birth, Mother and her fiancé filed a petition to terminate Father's parental rights and allow the fiancé to adopt the child. Mother did not serve the petition on Father, and he did not participate in the proceedings. The magistrate court terminated Father's parental rights and granted the adoption. Father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. This appeal concerns Father's second motion.The magistrate court denied Father's second motion, finding it barred by res judicata. The district court disagreed, reversed the magistrate court's order, and remanded the matter for the magistrate court to consider the motion on its merits. Mother appealed, arguing that Father's motion was barred by procedural doctrines, including res judicata and waiver.The Supreme Court of Idaho held that Father's Rule 60(b)(4) motion alleged a fundamental error that deprived him of his right to procedural due process, which in turn violated his fundamental constitutional right to raise his child. The Court concluded that the fundamental error doctrine applies to create an exception to the doctrines of res judicata and waiver. The Court affirmed the district court's decision and remanded the matter to the magistrate court to hold an evidentiary hearing to determine whether Father's Rule 60(b)(4) motion was timely and, if so, whether the termination and adoption judgment is void. The Court also awarded partial attorney fees to Father for defending against certain arguments raised by Mother on appeal. View "Doe v. Doe" on Justia Law

Elizabeth Corey Raber (Mother) and Michael Robert Raber (Father) married in 2019 in Texas and had one child. They moved to Coeur d’Alene, Idaho, in June 2020. Their relationship involved significant conflict, including a domestic dispute in June 2020 and a felony domestic battery charge against Father in December 2021, which was later dismissed. They separated, and Mother filed for divorce in January 2022, requesting joint legal and physical custody but primary physical custody and permission to relocate to Texas with the child. Father initially sought sole custody but later requested joint custody with equal time.The magistrate court ordered a Parenting Time Evaluation (PTE), which recommended joint legal custody with Mother having sole decision-making authority over schooling and routine medical care. The PTE also recommended that Mother have primary physical custody and be allowed to relocate to Houston. The magistrate court proposed two custody options: one where the child would stay in Idaho with a week-on/week-off schedule, and another where the child would fly between Idaho and Texas every two weeks. The court entered a judgment based on the second option after Mother relocated to Texas.The Supreme Court of Idaho reviewed the case and found that the magistrate court failed to consider all relevant factors, including the impact of the child traveling 2,000 miles every two weeks and the effect on the child’s education and stability. The court held that the magistrate court abused its discretion by not making a specific determination regarding the best interests of the child. The judgment was vacated, and the case was remanded for further proceedings to properly analyze the best interests of the child and consider all relevant factors. The court declined to award costs on appeal, as there was no prevailing party. View "Raber v. Raber" on Justia Law

In this case, the paternal grandmother, Natasha Ray, was appointed as the temporary guardian of a minor child shortly after the child's birth in 2015, with the father's consent. Over the next five years, the child's parents, Anthony Lowman and Kayla Morgan-Smart, contested the temporary guardianship. The magistrate court found no grounds to grant a permanent guardianship to the grandmother and aimed to reunify the child with the parents through a phased visitation plan. Despite this, the grandmother was held in contempt multiple times for failing to comply with court orders regarding visitation.The grandmother appealed the magistrate court's decisions to the district court. However, neither she nor her attorney, Wm. Breck Seiniger, filed the required opening briefs. The district court dismissed the appeal due to the failure to file timely briefs and found no good cause for the delay. The grandmother then filed a new notice of appeal from a subsequent contempt judgment, but again failed to file the necessary briefs on time, leading to the dismissal of the second appeal as well.The Supreme Court of Idaho reviewed the case and determined that Seiniger did not have the authority to represent the child, as he was never appointed by the magistrate court. The court also noted that the grandmother failed to challenge the district court's dismissal of her appeals in her briefing. Consequently, the Supreme Court affirmed the district court's decisions to dismiss the appeals and struck Seiniger's petition to intervene and notices of joinder. View "Ray v. Morgan-Smart" on Justia Law

Dan Lee Gearhart and Kristin A. Marlar divorced in September 2018, with Gearhart ordered to pay monthly child support. Gearhart applied for Social Security Disability Insurance (SSDI) benefits for himself and his children, which were approved after the divorce, with payments retroactive to August 2018. The children’s benefits were paid to Marlar as their representative payee. Gearhart stopped making child support payments, believing the SSDI payments covered his obligation. In May 2022, Gearhart petitioned the magistrate court to credit the SSDI payments against his child support arrearage, effectively reducing it to $0.00. Marlar opposed this, arguing it constituted a retroactive modification of child support.The magistrate court credited the SSDI payments against Gearhart’s arrearage, eliminating his outstanding balance. Marlar appealed to the district court, which reversed the magistrate court’s decision, concluding that Idaho Code section 32-709 prohibited retroactive modification of child support. The district court remanded the case with instructions to deny the application of SSDI payments as a credit against Gearhart’s arrearage.The Supreme Court of Idaho reviewed the case and reversed the district court’s decision. The Supreme Court held that Idaho Code section 32-709 did not apply to Gearhart’s petition because he was not seeking a modification of his child support obligation but rather a credit for SSDI payments already made. The court concluded that section 32-709(2) did not limit the magistrate court’s discretion to credit SSDI benefits against the child support arrearage. The case was remanded to the district court with instructions to reinstate the magistrate court’s judgment crediting the SSDI payments against Gearhart’s arrearage. Neither party was awarded attorney fees on appeal. View "Marlar v. Gearhart" on Justia Law

A child was born to Anthony Lowman and Kayla Morgan-Smart in 2015. The child's paternal grandmother, Natasha Ray, was appointed as her temporary guardian shortly after birth. Ray was later allowed to intervene in the parents' divorce action to determine custody once the guardianship ended in August 2021. Before the guardianship ended, attorney Wm. Breck Seiniger, Jr. was asked by Ray to represent the child, which he accepted without court appointment. Seiniger filed a notice of appearance in the divorce action, which the parents objected to. The magistrate court ruled that Seiniger could not represent the child as there was no motion to appoint counsel, it was unnecessary at that stage, and a neutral attorney would be appointed if needed.The parents reached a custody agreement and filed a stipulation for joint custody. Despite the magistrate court's ruling, Seiniger objected to the proposed judgment on behalf of the child. The magistrate court overruled the objections and entered a judgment consistent with the parents' stipulation. Ray appealed the custody judgment to the district court, joined by Seiniger. The district court concluded that Seiniger had no authority to represent the child and dismissed the appeal, characterizing Seiniger as an "officious interloper." Ray's appeal was later dismissed for failure to provide timely briefing.The Supreme Court of Idaho reviewed the case and affirmed the district court's decision. The court held that the magistrate court acted within its discretion in rejecting Seiniger's representation of the child, as there was no motion to appoint counsel and it was unnecessary at that stage. The court also found that Seiniger's arguments were unpreserved and unsupported by sufficient authority. Consequently, the district court's order, including the decision to strike all pleadings filed by Seiniger, was affirmed. View "Lowman v. Morgan-Smart" on Justia Law

A mother and her fiancé filed a petition to terminate the biological father's parental rights and allow the fiancé to adopt the child. The mother did not serve the father with the petition, and he did not participate in the proceedings. The magistrate court terminated the father's parental rights and granted the adoption. The father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. The magistrate court denied the second motion, citing res judicata. The district court reversed this decision, finding that the father's due process argument warranted consideration.The Idaho Supreme Court reviewed the case. The court held that the father's Rule 60(b)(4) motion, which alleged a fundamental error violating his constitutional right to due process, was not barred by res judicata. The court applied the fundamental error doctrine, which allows for exceptions to procedural bars when a fundamental constitutional right is at stake. The court also rejected the mother's arguments that the father's motion was barred by the doctrines of claim splitting, invited error, appellate waiver, and the law of the case.The Idaho Supreme Court affirmed the district court's decision to remand the case to the magistrate court for an evidentiary hearing to determine whether the father's Rule 60(b)(4) motion was timely and whether the termination and adoption judgment was void. The court also awarded the father partial attorney fees on appeal for defending against certain arguments made by the mother. View "Doe v. Doe" on Justia Law

Husband and Wife divorced in 2020, with Husband required to pay child support and attorney fees. Two years later, Wife initiated a contempt proceeding against Husband for failing to comply with the divorce decree. On the day of the contempt trial, Husband informed the court he was unable to attend due to vehicle issues. The magistrate court proceeded with the trial in his absence, found him in criminal contempt, and sentenced him to 70 days in jail, with 50 days suspended, and ordered him to pay additional attorney fees.The district court affirmed the magistrate court's decision to hold the trial in Husband's absence but reversed the incarceration sanction, finding insufficient evidence that Husband waived his right to counsel. The district court concluded that the magistrate court violated Idaho Rule of Civil Procedure 75(l)(1) by imposing incarceration without an attorney present to represent Husband.The Idaho Supreme Court reviewed the case and determined that the magistrate court erred in holding the contempt trial in Husband's absence. The court held that a contemnor's right to be present at a criminal contempt trial is protected under the Sixth Amendment, similar to a criminal defendant's right. The court concluded that Husband's willful absence did not constitute a knowing, intelligent, and voluntary waiver of his right to be present. The proper procedure would have been to issue a writ of attachment to ensure Husband's attendance.The Idaho Supreme Court reversed the district court's decision and remanded the case with instructions to vacate the order of contempt and remand to the magistrate court for further proceedings. The court also found the district court's failure to address Wife's request for attorney fees harmless, as Husband's appeal was not frivolous. No attorney fees were awarded on appeal, and costs were awarded to Husband. View "Salazar v. Salazar" on Justia Law

Jennifer and Jesse Smith divorced in 2017 after fifteen years of marriage. Jennifer, a stay-at-home mother, and Jesse, a construction superintendent, entered into a Marital Settlement Agreement requiring Jesse to pay Jennifer spousal support until January 1, 2025. The agreement included a "Review Term" stating that spousal support would be reviewed every two years. In 2018, Jesse unilaterally reduced the spousal support payments and later stopped paying altogether, leading Jennifer to file a breach of contract action.The magistrate judge dismissed Jesse's petition to modify the spousal support due to a non-merger clause, which kept the spousal support provision outside the court's jurisdiction. Jennifer then sought partial summary judgment in district court, arguing that the Review Term was too vague to be enforceable. The district court agreed, striking the Review Term but upholding the rest of the spousal support provision under the agreement's severability clause. The jury found Jesse in breach of the agreement and awarded Jennifer $76,514 in damages, plus attorney fees and costs.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the Review Term was unenforceable due to its vagueness, indefiniteness, and uncertainty. The court also upheld the district court's application of the severability clause, maintaining the enforceability of the remaining spousal support provision. Jennifer was awarded attorney fees and costs on appeal as the prevailing party. View "Smith v. Smith" on Justia Law

James Wilson and Jillian Wilson, who were married and had one minor child, divorced, leading to a custody dispute. The magistrate court awarded primary physical custody to Jillian and allowed her to relocate with the child to Australia, where both hold citizenship. Jillian was also granted sole legal custody over educational and medical decisions, while James was given two weeks of visitation annually during school breaks. James appealed the decision.The magistrate court's decision was based on several factors, including the unhealthy relationship between James and the child, characterized by controlling and manipulative behavior. The court found that James's actions, such as co-sleeping and inappropriate touching, created an environment that could potentially harm the child. The court also considered Jillian's motivations for relocating, including better family support and higher income prospects in Australia.The Supreme Court of Idaho reviewed the case and affirmed the magistrate court's decision. The court held that the magistrate court did not abuse its discretion in allowing Jillian to relocate with the child, as the decision was supported by substantial and competent evidence. The court also found that the magistrate court correctly applied the legal standard for relocation and considered the best interests of the child.Additionally, the Supreme Court of Idaho upheld the magistrate court's decision to limit James's physical custody and visitation, as well as the award of sole legal custody to Jillian for educational and medical decisions. The court concluded that these decisions were in the best interests of the child and were supported by substantial evidence. Jillian was awarded attorney fees and costs on appeal. View "Wilson v. Wilson" on Justia Law