Justia Idaho Supreme Court Opinion Summaries

Defendant-appellant Jonathan Folk was convicted by jury on one felony count of sexual abuse of a child under sixteen years old. On appeal, Folk contended the district court made numerous evidentiary errors. Folk also argued that the district court erred by denying his motion for a judgment of acquittal and the prosecutor committed misconduct amounting to fundamental error in his closing argument. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Folk" on Justia Law

The issue this case presented for the Idaho Supreme Court’s review centered on a judgment dismissing claims against an attorney and a law firm that he later joined based upon an opinion letter issued by the attorney in his capacity as corporate counsel regarding the legality of a stock redemption agreement. The Appellant challenged the grant of summary judgment to the Respondents (attorney and law firm) and the amount of attorney fees awarded to them. After review, the Supreme Court affirmed the judgment dismissing the claims and the awards of attorney fees, and awarded attorney fees on appeal. View "Taylor v. Riley" on Justia Law

Darol Anderson appealed his convictions for felony domestic battery and misdemeanor domestic battery, arguing the district court erred when it admitted the preliminary hearing testimony of his alleged victim, Erica Messerly, after finding that she was unavailable to testify at his trial due to mental illness. Anderson also argued the district court abused its discretion when it allowed a responding officer to testify that the injuries that he had observed on Messerly’s person were consistent with her allegations against Anderson. Anderson contended the officer’s testimony constituted impermissible vouching for Messerly’s truthfulness. The Idaho Supreme Court found the district court erred in admitting Messerly’s testimony from the preliminary hearing in this case because the State failed to establish Messerly was unavailable to testify. The Court affirmed the conviction in all other respects. View "Idaho v. Anderson" on Justia Law

The Idaho Supreme Court addressed the issue of whether a prescriptive easement across a parcel of land was extinguished by operation of former Idaho Code section 63-10091 when that parcel was sold by tax deed. The Owens purchased a small parcel of land (“the Orphan Parcel”) from Kootenai County after a tax sale. A dispute arose as to whether the Regans had the right to drive across the parcel. The Regans sued the Owens to reform the tax deed to include an express easement and to establish a prescriptive easement. The district court granted summary judgment in favor of the Regans, finding the Owens’ deed contained a mutual mistake and should be reformed to reflect an express easement that the original grantors intended. The Owens appealed and the Supreme Court held that the deed should not be reformed, vacated a portion of the district court’s judgment, and remanded for further proceedings. On remand, the district court granted summary judgment in favor of the Owens, finding that any prescriptive easement was extinguished by Idaho Code section 63-1009. The Regans appealed, but shortly after filing, the Idaho Legislature amended Idaho Code section 63-1009. The new version of 63-1009 did not apply retroactively, and the Supreme Court determined the trial court was correct in finding any prescriptive easement was extinguished by the old law. View "Regan v. Owen" on Justia Law

This case involved Arthur Watkins’ (Father) attempt to recover damages based on a default by his son, Arnold Douglas Watkins (Son or Doug), under a real estate installment contract. The question presented for the Idaho Supreme Court’s review was whether the complaint gave adequate notice of the election to accelerate the debt as required by Washington law. Son also brought a counterclaim for breach of a compensation agreement executed by a sibling acting on behalf of Father using a power of attorney. The compensation agreement purported to obligate Father to pay Son $3,000 per month for life. Father argued that the compensation agreement lacked consideration. The district court held a bench trial and ultimately found in favor of Father on his breach of contract claim and on the counterclaim brought against him. Son appealed. The Supreme Court found that the district court: (1) erred in concluding Father was not required to give notice of the acceleration; and (2) was correct in concluding the compensation agreement was unenforceable for lack of consideration. View "Watkins v. Watkins" on Justia Law

At issue in this appeal was a judgment dismissing an action seeking to recover money unlawfully collected by the City of Pocatello from users of the City’s water and sewer systems. In 2005, the city government decided that the City should be able to operate its water and sewer systems at a profit like private utilities. By law, the City was required to charge and collect sufficient fees so that its water and sewer systems “shall be and always remain self-supporting.” Those fees had to be sufficient to pay when due all bonds and interest as required by Idaho Code section 50-1032(a) and “to provide for all expenses of operation and maintenance of such works . . . , including reserves therefor,” as required by Idaho Code section 50-1032(b). The City wanted to obtain a profit in excess of the amounts necessary for the water and sewer systems to remain self-supporting. This profit was paid into the general fund. The City instituted a program called "PILOT," which stood for payment in lieu of taxes, under which city-owned water and sewer departments paid "property taxes" to the City as if they were private entities, and the departments then passed this cost on to their customers. The “property taxes” were then paid into the City’s general fund. Plaintiffs sought a refund of the PILOT sums that they had paid. In granting summary judgment, the district court held that the imposition of the PILOT was not a compensable taking. The district court appeared to rely upon two grounds for that decision: (1) "Some courts have made that determination on the grounds that money is not 'property' within the meaning of the Takings Clause," and (2) "Other courts ‘have concluded that governmental-imposed obligations to pay money are not the sort of governmental actions subject to a takings analysis.?” The Idaho Supreme Court determined both of these rationales were incorrect, reversed and remanded for further proceedings. View "Hill-Vu Mobile Home Pk v. City of Pocatello" on Justia Law

Sharon Hammer appealed a district court’s order dismissing her complaint. Hammer’s action against Nils Ribi alleged that he assaulted her during a city council meeting on September 15, 2011. Hammer was employed as City Administrator for Sun Valley, and Ribi was a member of the city council. Hammer’s alleged that, during a break in the meeting, Hammer left the council chambers to copy some documents. Ribi followed Hammer and demanded that she make certain changes to budget documents. Hammer refused. Ribi raised his arms; Hammer was afraid Ribi was going to hit her, and she stepped back. Hammer’s complaint alleged that Ribi had committed a civil assault. The district court granted Ribi’s motion to dismiss for failure to state a claim upon which relief could be granted. The district court denied Hammer’s motion to require Ribi to undergo a mental examination and ruled that Hammer failed to plead facts which would show that Ribi was not immune from suit under the Idaho Tort Claims Act (ITCA). The Idaho Supreme Court concluded the district court erred in dismissing Hammer's complaint for failing to state a claim. The district court did not abuse its discretion in denying Hammer's motion to compel a mental health examination. The Supreme Court vacated the judgment dismissing Hammer’s lawsuit and remanded for further proceedings. View "Hammer v. Ribi" on Justia Law

Matthew Cohagan appealed the district court’s denial of his motion to suppress. Following the denial of his motion, Cohagan entered a conditional guilty plea to possession of methamphetamine. Cohagan argued on appeal that the evidence seized when he was arrested should have been suppressed because it was “the direct result of the illegal detention because Officer Curtis detained [him] so that he could run a warrant check.” The Idaho Supreme Court determined there was no reason for the arresting officers to initiate a traffic stop in the first instance, so the evidence seized thereafter was indeed, the result of an illegal detention. The Court therefore reversed the denial of the motion to suppress and remanded for further proceedings. View "Idaho v. Cohagan" on Justia Law

While employed by Zing LLC, Josue Barrios (“Claimant”) was totally and permanently disabled as a result of an industrial accident when he fell about twelve feet from a ladder and hit his head face first on a concrete floor. He suffered multiple facial fractures, a frontal bone fracture, the loss of sight in his left eye, and a severe traumatic brain injury that caused a major neurocognitive disorder and speech language deficits. This case was an appeal of an Industrial Commission order requiring an employer and its surety to pay the cost of a guardian and a conservator for Barrios. Finding no reversible error in the Commission's order, the Idaho Supreme Court affirmed. View "Barrios v. Zing, LLC" on Justia Law

This appeal presents a narrow question of law relating to state income tax liability. Zippora Stahl was an Idaho resident who died in 2010. At the time of her death, Stahl owned real property located in Chino, California that had substantially appreciated in value. The Estate made a "1022 Election" following the sale of the Chino property in its 2012 federal income tax return. The Estate also filed an Idaho income tax return for 2012. When it did so, the Estate initially used the same modified carryover basis for the Chino property as it had for its federal income tax return. The Estate computed its state tax liability as $1,029,107, which the Estate paid. The Idaho State Tax Commission processed the Estate’s 2012 Idaho income tax return and determined that the Estate had incorrectly computed a credit for taxes paid to other states. Kathleen Krucker, personal representative of the Estate, appealed the district court’s grant of summary judgment in favor of the Commission and the district court’s denial of the Estate’s motion for reconsideration. The district court held that the Estate could not use a different figure as the starting point for calculating its Idaho taxable income for 2012 than it reported to the Internal Revenue Service for that year. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "Krucker v. Idaho State Tax Commission" on Justia Law