Justia Idaho Supreme Court Opinion Summaries

In this case, the State of Idaho removed five minor children from their parents' home following allegations of physical abuse. The children ranged in age from sixteen years to fourteen months. Law enforcement responded to a report of an altercation between the mother and the eldest child, during which the mother admitted to hitting the child with a plastic hanger. Other children reported frequent physical discipline, including being hit with belts and hands. The children were declared to be in imminent danger and were removed from the home.The Bannock County Prosecutor’s Office filed a petition under the Child Protective Act (CPA) to place the children in the custody of the Idaho Department of Health and Welfare (IDHW). The magistrate court held a shelter care hearing and found reasonable cause to believe the children were in danger, placing them in temporary custody of IDHW. The parents objected, arguing that the removal violated their constitutional rights and that the magistrate court’s findings were unsupported by substantial evidence.The Idaho Supreme Court reviewed the case and affirmed the magistrate court’s adjudicatory decree. The Court declined to rule on the constitutionality of the initial removal because the parents failed to raise the issue in the lower court. The Court also found that the challenge to the shelter care order was moot because it was supplanted by the adjudicatory decree. The Court held that the magistrate court did not abuse its discretion by allowing the older children to remain in the courtroom during the hearing and found that substantial and competent evidence supported the magistrate court’s decision to vest legal custody of the children in IDHW. The Court also declined to consider the parents' argument under the Idaho Parental Rights Act because it was raised for the first time on appeal. View "IDHW v. Doe" on Justia Law

In June 2016, Peter Franklin Goullette was driving with his child in the backseat when he struck and killed Kathy Stelzer and severely injured Zualita Updike, who were walking on the road. Goullette admitted to officers that he was attempting to buckle his son back in when he struck the victims. He was charged with vehicular manslaughter and reckless driving. Goullette entered a guilty plea while maintaining his innocence, known as an Alford plea. He later appealed his conviction, arguing that the district court abused its discretion when it accepted his guilty plea because it failed to inquire into the factual basis of his guilty plea.The case was first heard in the District Court of the First Judicial District of the State of Idaho, Bonner County, where Goullette was convicted. He then appealed to the Idaho Court of Appeals, which affirmed his conviction. Goullette subsequently filed a petition for review with the Supreme Court of the State of Idaho.The Supreme Court of the State of Idaho affirmed Goullette's conviction. The court held that the district court did not err in accepting Goullette’s Alford plea because the record as a whole demonstrated that Goullette entered a knowing, voluntary, and intelligent plea. The court also held that the district court did not err by failing to revisit the validity of Goullette’s plea at sentencing because the district court was not presented with evidence raising an obvious doubt as to Goullette’s guilt. View "State v. Goullette" on Justia Law

In this case, Develin Johnson appealed against the district court's decision that upheld his convictions for domestic battery and false imprisonment. The key issue in the appeal was the admissibility of Johnson's previous misdemeanor conviction for petit theft under Idaho Rule of Evidence 608(b) and whether the probative value of the evidence was substantially outweighed by the risk of unfair prejudice. Johnson argued that the district court erred in affirming the judgment of conviction because his misdemeanor conviction for theft was inadmissible under Idaho Rule of Evidence 608(b) and the probative value of the evidence was substantially outweighed by a danger of unfair prejudice. The Supreme Court of the State of Idaho affirmed the district court's decision, holding that the conduct leading to Johnson's 2013 misdemeanor conviction was probative of his character for truthfulness and that the prejudicial effect of the evidence did not substantially outweigh its probative value. View "State v. Johnson" on Justia Law

In this case, defendant Douglas Shane Thompson was convicted for domestic violence, and a no-contact order was put in place prohibiting him from contacting his minor son. Thompson appealed against the decision, arguing that there was no evidence that he posed a threat to his son and that the no-contact order violated his fundamental right to parent his son.The Supreme Court of the State of Idaho found that the lower court failed to provide adequate reasons for amending the no-contact order to prohibit all contact between Thompson and his son. The court concluded that the lower court did not exercise reason since it did not articulate any evidence that demonstrated a change in circumstances that justified the amendment of the no-contact order. It was also noted that the court did not explain what circumstances would need to change before Thompson could seek to reinitiate contact with his son.The court also observed that Thompson's argument that the no-contact order effectively terminated his parental rights was not sufficiently preserved for appeal. The court acknowledged the complexities when a judge not regularly dealing with family law issues has to analyze often competing interests involved.Therefore, the court reversed the decision of the lower court to amend the no-contact order and remanded the case back to the district court for further proceedings. View "State v. Thompson" on Justia Law

Marianita Martinez alleged that after she and Victorio Carretero divorced in April 1995, they subsequently entered into a common law marriage between their divorce in April 1995 and their move to California in November 1995. After filing of cross-motions for summary judgment on the common law marriage issue, the magistrate court proceeded to hold an evidentiary hearing without ruling on the motions and without objection from either party. At the evidentiary hearing, the magistrate court excluded all evidence of the parties’ conduct on or after January 1, 1996, as being irrelevant to whether the parties had entered into a common law marriage prior to that date. This ruling resulted in the exclusion of, among other things, evidence of a life insurance application in which Carretero identified Martinez as his “wife” on January 10, 1996—two months after the parties left Idaho in November 1995. At the close of the hearing, the magistrate court concluded there was not sufficient evidence to show that the parties had consented to marry within the seven-month period prior to January 1, 1996. The magistrate court then dismissed Martinez’s claim of a common law marriage, and on appellate review, the district court affirmed. The Idaho Supreme Court affirmed in part, reversed in part, and remand. The Supreme Court found any error in the magistrate court’s decision to conduct an evidentiary hearing before ruling on the pending cross-motions for summary judgment was invited and not preserved for appeal. The magistrate court erred by excluding evidence of the parties’ conduct after December 31, 1995, and by granting Carretero’s motion for an involuntary dismissal. The case was remanded with instructions that the district court remand this matter to the magistrate court for further proceedings. View "Martinez v. Carretero" on Justia Law

The parents in this case were brought to the attention of the Idaho Department of Health and Welfare ("Department") regarding reports of neglect and physical abuse to their five children. The child protection case began in February 2023 as a protective supervision case. Nearly three months later, the magistrate court ordered that the children be removed from the home and placed in the legal custody of the Department. John Doe (Father) appealed the magistrate court’s order removing his five children from the parents’ custody and temporarily placing the children in the legal custody of the Department. Father argued the magistrate court’s order failed to contain detailed written findings as required by Idaho law, that the order was not supported by substantial and competent evidence, and that the magistrate court’s actions violated Father’s fundamental rights to the care and custody of his children. Finding no reversible error, the Idaho Supreme Court affirmed the magistrate court. View "IDHW v. John Doe" on Justia Law

In this appeal, the Idaho Supreme Court addressed a challenge to a magistrate court’s decision to take jurisdiction of an infant after finding that the infant was “at risk of being a victim of abuse, neglect, or abandonment.” The Idaho Department of Health and Welfare (“IDHW” or “Department”) filed a Child Protective Act (“CPA”) petition pursuant to Idaho Code section 16-1603(2) in March 2023 for an infant (“Infant”) who was about three months old. The magistrate court had jurisdiction over the infant’s older brother (“Toddler”), having removed Toddler at age eighteen months after determining Toddler had been physically abused, neglected, and subjected to an unstable home. Infant was born about four months after Toddler was placed in foster care. At the adjudicatory hearing pertaining to Infant, the magistrate court found: (1) Mother and Father failed to make any progress whatsoever on the case plan associated with Toddler; (2) Mother and Father were unresponsive and uncooperative with the Department; (3) none of the safety issues that were identified as part of Toddler’s removal had been alleviated; and (4) Mother and Father consistently failed to comply with a court order for drug testing (including a urinalysis and hair follicle testing). The Supreme Court found no reversible error and affirmed the magistrate court’s decision. View "IDHW v. Jane Doe / IDHW v. John Doe" on Justia Law

This lawsuit arose from an investigation into whether Appellant Kristine McCreery abused or neglected her fifteen-year-old son, B.M. McCreery filed a complaint against two physicians who reported the alleged abuse, the detective who investigated the reports, the deputy prosecutor who filed the Child Protection Act (“CPA”) action, and the social worker for the Idaho Department of Health and Welfare who submitted an investigatory report and testified in the CPA case (collectively “defendants” or “Respondents”), alleging they had violated her constitutional rights and Idaho’s false reporting statutes when they took actions to separate her from B.M. for over fifteen months. The district court dismissed McCreery’s claims with prejudice after finding Respondents were immune from liability and that the allegations in McCreery’s complaint failed to state any valid claim upon which relief could be granted. McCreery moved to amend her complaint, which the district court denied. McCreery appealed to the Idaho Supreme Court, arguing that the district court erroneously dismissed her claims. The Supreme Court found no reversible error and affirmed. View "McCreery v. King, M.D., et al." on Justia Law

The issue this appeal presented centered on a non-summary contempt proceeding arising out of a divorce, and former litigation in Oregon over spousal support Steven Abell owed his ex-wife Debra Abell. After a judgment of contempt was entered against him in Oregon for failure to pay support, Steven allegedly continued to refuse to pay Debra. Roughly one year later, Debra brought the underlying contempt proceeding in Idaho, charging Steven with contempt for failure to comply with the payment terms in the Oregon contempt judgment, and requesting relief from the Idaho district court, where Steven resided. The district court found Steven in willful contempt of the Oregon contempt judgment, and imposed an unconditional sanction of $5,000, making both determinations through a summary judgment procedure. Steven appealed. The Idaho Supreme Court found the sanction imposed by the district court was criminal in nature, and it was imposed in error because Steven was not afforded certain protections owed an alleged contemnor in a criminal contempt proceeding. In addition, regardless of whether a civil or criminal sanction is sought or imposed, when an alleged contemnor is not in default and denies the charge of contempt, the non-summary contempt proceeding cannot be adjudicated through a summary judgment procedure. Idaho Rule of Civil Procedure 75 requires a trial. Accordingly, the district court’s judgment of contempt was vacated, its decisions underlying its judgment were also vacated, and the case was remanded for further proceedings that had to start over, at the initial pleading stage, in order to proceed appropriately. View "Abell v. Abell" on Justia Law

Tiffani Finco appealed a district court’s decision, acting in its appellate capacity, remanding a petition to modify child custody to the magistrate court for further proceedings. The Idaho Supreme Court dismissed the appeal because it was moot. View "Edmonson v. Finco" on Justia Law