Justia Idaho Supreme Court Opinion Summaries

Desiree Elaine Karst was a passenger in a car stopped by police in Kootenai County, Idaho. During the stop, a drug dog alerted to the presence of drugs, and Karst admitted to having drugs in the car. Additional drugs and paraphernalia were found on her at the jail. She was charged with multiple drug offenses and introducing contraband into a correctional facility. Karst moved to suppress the evidence, arguing the stop was impermissibly extended. The district court partially denied her motion, and Karst entered conditional guilty pleas, reserving her right to appeal. She was ordered to pay $569.50 in various court fees.Karst appealed the partial denial of her motion to suppress. The Idaho Supreme Court found the traffic stop was impermissibly extended, reversed the district court’s decision, and remanded the case. Subsequently, the prosecutor dismissed all charges against Karst. Karst then filed a motion to reimburse the fees she had paid, arguing that retaining her funds violated her due process rights. The district court denied her motion, citing a lack of jurisdiction and suggesting she sue each governmental entity that received the fees.The Idaho Supreme Court reviewed the case and held that the district court had both personal and subject matter jurisdiction to consider Karst’s motion for reimbursement. The court found that the State, by initiating the criminal case, had submitted to the district court’s jurisdiction. The court also determined that requiring Karst to file multiple civil suits to recover the fees would impose more than minimal procedures, violating her due process rights. The court reversed the district court’s decision and remanded the case for further proceedings, instructing that Karst should be reimbursed if she proves she paid the fees and her conviction was invalidated. View "State v. Karst" on Justia Law

The case involves a dispute between Brian L. Porter, trustee of the Brian L. Porter Revocable Trust, and Marvin A. Remmich, manager of McMillan Storage LLC, an Idaho limited liability company. The conflict centers on the management of the LLC and the conduct of its members. Remmich initially filed a complaint in California against Porter, alleging various breaches related to the construction of the LLC’s storage facility. Porter later filed a complaint in Idaho, accusing Remmich of mismanaging the LLC. Both parties reside in California, and the LLC’s principal place of business is also in California.In the California action, the court denied Porter’s motion to dismiss on grounds of forum non conveniens, retaining jurisdiction over the case. Subsequently, the Idaho District Court dismissed Porter’s claims without prejudice under Idaho Rule of Civil Procedure 12(b)(8), which allows for dismissal when another action between the same parties for the same cause is pending. The district court reasoned that the California court could adjudicate the entire controversy, and concurrent litigation would lead to increased costs and potentially inconsistent judgments.The Supreme Court of Idaho affirmed the district court’s decision. It held that the district court did not abuse its discretion in dismissing the Idaho action. The court found that the parties and claims in both actions were essentially the same, and the California court was in a position to resolve the entire dispute. The court emphasized considerations of judicial economy, minimizing litigation costs, and avoiding inconsistent judgments. Consequently, the Idaho action was dismissed without prejudice, and Porter was directed to pursue his claims in the California court. View "Porter v. Remmich" on Justia Law

The case involves a failed business relationship between Mike Jones, Jeremy Sligar, and Sligar's business, Overtime Garage, LLC. Jones claimed they formed a joint venture in 2011 to buy and sell used vehicles, which Sligar disputed. The relationship deteriorated, and Sligar terminated the venture in 2016. Jones filed a complaint in 2016 seeking a declaratory judgment, dissolution of the joint venture, and other relief. Sligar counterclaimed for similar relief. During the litigation, Safaris Unlimited, LLC, bought Jones's interest in the case at a sheriff's sale and settled the case by dismissing Jones's claims against Sligar.The District Court of the Fifth Judicial District, Twin Falls County, denied Jones's motion to set aside the judgment in the first case (Sligar I) and granted summary judgment to Sligar in the second case (Sligar II), finding that Jones's claims were barred by res judicata. The court also awarded attorney fees to Sligar and Safaris, finding Jones's motion to set aside the judgment was frivolous and untimely. Jones appealed these decisions, arguing the consolidation of small claims actions with Sligar I was improper and that his Rule 60(b) motion was timely.The Supreme Court of Idaho affirmed the district court's decisions. It held that the consolidation of the small claims actions with Sligar I was proper, as the small claims were related to the disputed property in Sligar I. The court also found that Jones did not file his Rule 60(b) motion within a reasonable time, as he delayed over five months without a valid reason. Additionally, the court upheld the summary judgment in Sligar II, agreeing that Jones's claims were barred by res judicata. The court awarded attorney fees to Sligar for the appeal in Sligar I but not in Sligar II, as Sligar did not prevail on its cross-appeal. View "Jones v. Sligar" on Justia Law

In 1988, Rodney Araiza was involved in a riot at the Idaho State Penitentiary, during which an inmate named Richard Holmes was murdered. Araiza was charged with first-degree murder and participating in the riot. At trial, the State presented evidence, including testimonies and Araiza’s bloody palm prints, suggesting Araiza's involvement in the murder. Araiza defended himself by claiming he arrived at Holmes' cell after the murder. Despite his defense, Araiza was convicted by a jury on both charges in 1989.After his conviction, Araiza filed a motion for a new trial, presenting new evidence, including a confession from another inmate, Merle LaMere, who claimed responsibility for the murder. However, the district court denied the motion, finding the new evidence unlikely to result in an acquittal. Araiza was sentenced to life imprisonment for murder and 20 years for riot, to be served concurrently. Araiza's subsequent appeals, including a direct appeal, were unsuccessful.In 2019, Araiza filed a petition for post-conviction relief, claiming actual innocence and requesting DNA and fingerprint testing. The district court dismissed the petition, stating that the DNA evidence would not likely prove Araiza's innocence and that his claims were barred by res judicata. Araiza did not receive notice of this dismissal until after the appeal period had expired. He then filed a motion for relief from judgment under Idaho Rules of Civil Procedure 60(b)(1) and 60(b)(6), which led to the district court reentering judgment.Araiza appealed the reentered judgment, but the Idaho Court of Appeals dismissed the appeal as untimely. The Supreme Court of Idaho reviewed the case and concluded that Araiza's appeal was indeed untimely, as his motion for relief from judgment was filed outside the six-month limit for Rule 60(b)(1) motions. Consequently, the Supreme Court dismissed Araiza’s appeal for lack of jurisdiction. View "Araiza v. State" on Justia Law

In 2018, Brian Hollis pleaded guilty to one count of lewd conduct with a minor under sixteen and four counts of sexual exploitation of a child. He also admitted to being a repeat sexual offender, which mandates a fifteen-year minimum term of confinement. The district court imposed an indeterminate life sentence with twenty-five years determinate on the lewd conduct charge and concurrent determinate sentences of fifteen years for each of the sexual exploitation charges. Hollis appealed his conviction and sentence, but the Idaho Court of Appeals affirmed them.Hollis then filed a pro se petition for post-conviction relief, alleging ineffective assistance of trial counsel. The district court appointed the Kootenai County Public Defender to represent him. However, Hollis' conflict counsel filed a motion to withdraw, stating that he was no longer able to "ethically or effectively represent" Hollis due to statements made by the district court judge against conflict counsel in a similar post-conviction case. The district court denied the motion to withdraw and the motion to continue the summary disposition hearing. The district court subsequently granted the State’s motion for summary disposition, holding that Hollis had not supported any of his claims with any admissible evidence.The Supreme Court of the State of Idaho vacated the judgment of the district court, reversed the decisions on the motion to continue and motion to withdraw, vacated the decision granting summary disposition to the State, and remanded for further proceedings. The court held that the district court abused its discretion in denying the motion to withdraw and the motion to continue. The court also ordered the assignment of a new district court judge on remand. View "Hollis v. State" on Justia Law

The case revolves around Thomas E. Hennig, Jr., who was discharged from his job at Money Metals Exchange, L.L.C. after making a controversial comment on the company's instant messaging system. Hennig referred to himself as his employer’s “good little Nazi” in a joke about enforcing the company’s time clock rules. After his termination, Hennig applied for unemployment benefits, but his application was denied by the Idaho Department of Labor (IDOL) on the grounds that he was discharged for misconduct connected with his employment. Hennig appealed this decision to the Idaho Industrial Commission, which upheld the IDOL's decision.Hennig then appealed to the Supreme Court of the State of Idaho, arguing that the Commission’s decision was unsupported by competent and substantial evidence. He contended that his use of the term "Nazi" was not objectively unprofessional and that the company had tolerated racist remarks from another employee. The Supreme Court of Idaho reversed the Commission’s decision and remanded the case for further proceedings. The court found that the Commission had failed to properly analyze whether the company's expectations of Hennig's behavior were objectively reasonable, given evidence that it had tolerated racist comments from another co-worker and then promoted him to a supervisory position. The court also found that the Commission had failed to consider Hennig's claim that the company had encouraged his unorthodox humor. View "Hennig v. Money Metals Exchange" on Justia Law

This case involves an insurance dispute following a fatal car accident. Jay Lanningham was killed in a car accident caused by an underinsured motorist. Lanningham had an insurance policy with Farm Bureau Mutual Insurance Company of Idaho that included underinsured motorist (UIM) coverage. However, Farm Bureau denied the UIM claims made by Lanningham's adult children, Jeremy and Jamie, for their father's wrongful death. The insurance company argued that the siblings did not qualify as insured persons under the policy since they did not reside with Lanningham.The District Court of the Fourth Judicial District of the State of Idaho granted Farm Bureau's motion for summary judgment, ruling that the insurance company rightfully denied payment to Jamie and Jeremy as they did not qualify as insured persons under the policy.The Supreme Court of the State of Idaho affirmed the lower court's judgment in favor of Farm Bureau. The court found that the plain language of Lanningham’s insurance policy precluded non-insureds from recovering UIM benefits. The court also held that the policy did not violate Idaho Code section 49-1212(12), which prohibits reduced liability coverage for family or household members. Furthermore, the court found that the case law precedent, Farm Bureau Mutual Insurance Company of Idaho v. Eisenman, was applicable and remains good law. The court concluded that neither Jamie nor Jeremy, as non-insured heirs, could recover UIM benefits under the plain language of the policy and Idaho Code section 41-2502. View "Lanningham v. Farm Bureau" on Justia Law

This case involves a dispute between siblings Elizabeth and Jason Carter, who are both licensed dentists and co-owners of Carter Dental. In 2020, Jason accused Elizabeth of misusing the practice’s funds for her personal benefit. The parties agreed to mediation, which resulted in a settlement agreement that included a noncompete clause. Elizabeth later refused to sign a written mutual release, leading Jason to move to enforce the settlement agreement. The district court found the settlement agreement and noncompete clause enforceable and dismissed the case with prejudice. Elizabeth appealed, arguing that the noncompete clause and the settlement agreement were unenforceable.The Supreme Court of the State of Idaho affirmed the district court's judgments. The court found that Elizabeth was estopped from arguing that the settlement agreement was unenforceable because she had not appealed the district court’s dismissal of the case with prejudice. The court also held that the district court did not err in awarding attorney fees and costs to Jason and Carter Dental. The court concluded that Jason and Carter Dental were entitled to attorney fees and costs on appeal. View "Carter Dental v. Carter" on Justia Law

This case involves a dispute between two neighboring landowners, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP) and Michael Reid, an individual. The dispute arose from a settlement agreement concerning the real property and easement rights of the two parties. Axelrod purchased a property in Teton County in 2003, which was not accessible by road. Reid, who owned and operated an organic dairy farm nearby, preferred Axelrod to build onto an existing dirt road on Reid's property rather than using two easements provided in Axelrod's deed. In 2004, Axelrod built onto the existing dirt road, referred to as the "RLP Easement." However, the relationship between Axelrod and Reid began to sour in 2011, leading to a series of disputes and legal actions.The district court initially concluded that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The parties then executed a settlement agreement and stipulated to dismiss the suit. However, disagreements over the implementation of the settlement agreement led to further litigation. The district court granted Axelrod's motion for summary judgment, concluding that Reid had failed to properly support any assertion of fact or address the assertions of fact in Axelrod's motion for summary judgment.On appeal, the Supreme Court of the State of Idaho affirmed in part, vacated in part, and remanded the case for further proceedings. The court affirmed the grant of summary judgment against Reid individually and affirmed the district court's judgment dismissing RLP's counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The court also affirmed the judgment of the district court on Axelrod's breach of contract claim and the judgment of the district court refusing to allow amendment of the pleadings to add RFLP as a party. However, the court vacated the judgment of the district court dismissing RLP's trespass claim. The court also vacated the attorney fee award as against RLP and remanded for further proceedings consistent with this opinion. View "Axelrod v. Reid Limited Partnership" on Justia Law

The case revolves around John Thomas Bujak, who pleaded guilty to grand theft and was placed on probation with the condition of serving thirty days in jail. Bujak scheduled his jail time on weekends to maintain his employment during the week. After serving his first jail stay from Friday morning to Sunday morning, Bujak learned that he would receive credit for two days of jail time. He then moved the district court for credit for time served, arguing that he should receive three days credit because he served time over the course of three calendar days.The district court denied Bujak’s motion, interpreting that the terms of its probation order required Bujak to serve thirty, twenty-four-hour periods in jail. Bujak appealed this decision, arguing that Idaho Code section 18-309 required the district court to award him one day of credit for each partial day of jail time he served.The Supreme Court of the State of Idaho affirmed the district court’s order. The court concluded that neither section 18-309 nor section 19-2603 applies to the calculation of Bujak’s time served. Instead, the court found that Idaho Code section 19-2601(3) controls, which allows a district court to withhold judgment and impose probation terms it deems necessary and appropriate. The court agreed with the district court's interpretation that Bujak was required to serve thirty, twenty-four-hour days in jail as a term of his probation. View "State v. Bujak" on Justia Law