Justia Idaho Supreme Court Opinion Summaries

Whitney Bright appealed the grant of summary judgment to Roman and Natalya Maznik. The Mazniks owned property who leased an apartment to James and Katherine Thomas, owners of a Belgian Shepherd. When Bright visited the Thomas’ apartment in an effort to collect on a debt, the Thomas’ dog attacked her. Bright then lodged a complaint against the Mazniks, alleging various tort claims arising from the attack. The district court granted the Mazniks’ motion for summary judgment, finding the Mazniks owed no duty to protect Bright from the Thomas' dog. Therefore, the district court's grant of summary judgment on Bright's tort claims was proper, and the Idaho Supreme Court affirmed. View "Bright v. Maznik" on Justia Law

Travis Forbush and Gretchen Hymas, individually and as natural parents of McQuen Forbush and Breanna Halowell (Appellants), appealed the grant of summary judgment to Respondents Sagecrest Multifamily Property Owners’ Association, Inc., and its President, Jon Kalsbeek. Forbush and Halowell were overnight guests of a tenant who leased a unit at the Sagecrest Apartment Complex (Sagecrest). During the night, hazardous levels of carbon monoxide filled the unit, killing Forbush and injuring Halowell. Appellants brought tort claims against Respondents after the incident. Appellants contended the district court erred by granting summary judgment to the POA because triable issues of fact surrounded whether the POA: (1) owed a premises liability-based duty of care; (2) owed a duty of care it acquired as a result of voluntary undertakings; and (3) was vicariously liable for First Rate Property Management's (FRPM - the POA's contract maintenance) conduct. The Idaho Supreme Court affirmed in part and reversed in part the district court’s summary judgment order. The Court affirmed that summary judgment was proper as to whether the POA owed a premises liability-based duty of care. However, summary judgment was improper as to whether the POA and Kalsbeek acquired a duty of care as a result of voluntary undertakings, and whether the POA was vicariously liable for FRPM’s conduct. View "Forbush & Hymas v. Sagecrest POA" on Justia Law

In 1981, a jury found Randy McKinney guilty of first degree murder (both by premeditated killing and by felony murder), conspiracy to commit murder, robbery, and conspiracy to commit robbery for the April 1981 shooting death of Robert Bishop, Jr. In 1982, the district court sentenced McKinney to death for first degree murder, an indeterminate thirty years for conspiracy to commit murder and conspiracy to commit robbery, and fixed life for robbery. In 1997, McKinney filed a petition for habeas corpus in federal district court, and in 2009, the court ruled that he was not entitled to any relief related to the guilt phase of his state case but that he was entitled to resentencing because of the ineffective assistance of his attorney at the capital sentencing hearing. Rather than appealing the court’s decision, the State and McKinney entered into a binding sentencing agreement titled “Rule 11 Sentencing Agreement” in which they agreed that McKinney would “be sentenced to a term of fixed life without the possibility of parole for the crime of first-degree murder, concurrent with his sentences for conspiracy to commit murder, robbery and conspiracy to commit robbery.” McKinney was sentenced in accordance with the plea agreement. In 2010, McKinney filed a motion pursuant to Idaho Criminal Rule 35 to correct an illegal sentence, contending that being sentenced for both robbery and first-degree murder was barred by the state and federal double jeopardy clauses and a multiple-punishment statute that was in effect when he committed the crimes. This motion was denied. Then in 2013, McKinney moved for post-conviction relief; the State moved to dismiss this petition. The district court found no genuine issue of material fact alleged, and dismissed the petition. McKinney appealed that dismissal, but finding no error in that judgment, the Idaho Supreme Court affirmed. View "McKinney v. Idaho" on Justia Law

In September 2012, the State charged Flores with one felony count of eluding a peace officer. Flores pled guilty to the charge. A judgment of conviction was entered, and Flores was sentenced to five years: a three-year determinate period of confinement followed by a two-year indeterminate period of confinement. The execution of the sentence was suspended and Flores was placed on probation for four years. The probation was revoked and the original sentence reinstated. However, execution of the sentence was again suspended and Flores was placed on probation again for two years. This probation was revoked and execution was suspended, during which time the district court retained jurisdiction over Flores. Roughly four months after the district court retained jurisdiction, the North Idaho Correctional Institution (NICI) filed an addendum to the presentence investigation report (NICI’s report), informing the district court that NICI had classified Flores as a security risk and removed him from the NICI facility. NICI’s report detailed Flores’s misconduct and gang-oriented behavior and recommended that the district court relinquish jurisdiction. The district court followed NICI’s recommendation and relinquished jurisdiction. Flores moved the district court to reinstate jurisdiction so that he could complete his retained jurisdiction program. The district court denied Flores’s motion. Flores appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Flores" on Justia Law

The State of Idaho appeals from the district court’s order suppressing evidence against Victor Garcia-Rodriguez. On April 10, 2014, Garcia-Rodriguez was pulled over after an Idaho State Police trooper witnessed Garcia-Rodriguez’s car briefly cross over the fog line while exiting Interstate 84. Approximately 75 minutes after the stop, police arrested Garcia-Rodriguez for failure to purchase a driver’s license. Otto conducted a search incident to arrest and found methamphetamine in Garcia-Rodriguez’s front pants pocket. This stop ultimately led to Garcia-Rodriguez’s arrest. Garcia-Rodriguez was charged with trafficking in methamphetamine and possession of paraphernalia. Garcia-Rodriguez filed a motion to suppress the evidence, which the district court granted. The Idaho Supreme Court found based on the evidence and testimony presented, the district court concluded that police did not have reasonable grounds to arrest Garcia-Rodriguez pursuant to Idaho Code section 49-1407 for the misdemeanor charge of driving without a license. Accordingly, the Court affirmed the district court's suppression order. View "Idaho v. Garcia-Rodriguez" on Justia Law

This appeal originated from a claim for attorney fees under Idaho Code section 12-117. The district court held that Hauser Lake Rod and Gun Club, Inc. was not entitled to attorney fees under section 12-117 because, even though it had prevailed against the City of Hauser in a code violation dispute, the administrative tribunal that reviewed the dispute was staffed with both County and City officials. According to the district court, section 12-117’s definition of “political subdivision” does not include administrative review tribunals staffed with officials from multiple governmental entities. The Idaho Supreme Court concluded the district court erroneously interpreted Idaho Code section 12-117 by concluding the Joint Board was not a “political subdivision:” the decision of the Board of County Commissioners was the act of a political subdivision. The statutory definition of a political subdivision expressly included counties. "As with any corporate body, a county may only act through its human agents. Under Idaho law, those agents are the Board because a county’s 'powers can only be exercised by the board of county commissioners, or by agents and officers acting under their authority, or authority of law.'" View "Hauser Lake Rod & Gun Club v. City of Hauser" on Justia Law

John Doe appealed a magistrate court’s decision terminating his parental rights. The magistrate court terminated Doe’s rights on the statutory basis of Idaho Code section 16-2005(1), namely, that Doe was incarcerated and is likely to remain incarcerated for a substantial period of time during his sons’ (A.C. and S.C.) minority. The court also found termination was in the best interests of A.C. and S.C. Finding no abuse of discretion, the Idaho Supreme Court affirmed the termination. View "Health & Welfare v. John Doe (2017-4)" on Justia Law

The issue at the center of this case, presented for the Idaho Supreme Court's review, required it to resolve a custody dispute between Jane Doe I, Child’s natural mother, and Jane Doe, the natural mother’s former partner. During the course of Mother and Partner’s relationship, Mother conceived a child via artificial insemination. After the parties separated, Partner filed a petition to establish parentage, custody and visitation with Child. Partner advanced two legal arguments to support her petition: (1) the Court’s decision in Stockwell v. Stockwell, 775 P.2d 611 (1989), provided an independent cause of action by which the court could grant custody to Partner; (2) argued that she should be deemed a parent under Idaho Code section 39-5405, Idaho’s artificial insemination statute, because she consented to the artificial insemination. As part of this argument, Partner contended that Idaho’s artificial insemination statute violated Child’s rights and her rights under the Equal Protection Clause of the United States Constitution by discriminating against children born outside of marriage. The magistrate court denied Partner’s claim for parentage, but granted her visitation rights under "Stockwell." After review, the Supreme Court concluded: (1) "Stockwell" did not create an independent cause of action for a non-parent seeking custodial rights to a minor child; and (2) the magistrate court properly dismissed the parentage claims brought pursuant to the Artificial Insemination Act. The judgment of the magistrate court was reversed in part and affirmed in part. The case was remanded to the magistrate court to vacate the temporary visitation order that was entered. View "Jane Doe v. Jane Doe I" on Justia Law

This was a legal malpractice case that addressed the statute of limitations applicable to professional malpractice claims, how a statute of limitations is calculated when the last day for filing a complaint falls on a Sunday, and whether expert testimony is necessary to establish the prima facie elements of legal malpractice. Plaintiff-appellant Christina Greenfield hired defendant-respondent Ian Smith to represent her in a civil suit against her neighbors. While the suit was pending, Greenfield was charged criminally with malicious injury to the Wurmlingers’ property. Greenfield retained Smith to represent her in the criminal matter. Greenfield was acquitted of the criminal charges. In the civil case, Smith successfully moved to withdraw from representing Greenfield because the attorney-client relationship had broken down to the point where he was no longer able to represent her. Greenfield represented herself at trial, and the jury returned a verdict in favor of the neighbors. Greenfield sued Smith for malpractice, alleging, among other things, that he failed to complete discovery, failed to file a motion for summary judgment on the Wurmlingers’ counterclaim for intentional infliction of emotional distress, failed to amend the complaint to include additional causes of action for abuse of process, slander and libel, failed to file a timely motion for protective order to safeguard the privacy of her medical records, missed several important deadlines, and made no attempt to get the criminal charges dismissed for lack of evidence. Smith filed a motion for summary judgment, arguing that Greenfield’s claims were time barred and that she could not prove the prima facie elements of legal malpractice because she failed to designate any expert witnesses. Greenfield opposed the motion by filing a responsive brief and her own affidavit setting forth the allegations she claimed supported her malpractice claim, but did not file any expert affidavits. Greenfield argued that her complaint was timely and that no expert witness was required to prove her case. The district court granted Smith’s motion. Greenfield appealed. Though the Idaho Supreme Court found that the district court miscalculated the filing deadline for Greenfield’s civil matter claims (for determining whether her claims were time barred), Greenfield was unable to meet her burdens of proof to support her claims. Accordingly, the Court affirmed judgment in favor of Smith. View "Greenfield v. Smith" on Justia Law

Jane Doe (“Doe”) appealed the magistrate court’s judgment granting the Idaho Department of Health and Welfare’s (“IDHW”) petition to terminate her parental rights. Doe claimed that the magistrate court erred by: (1) terminating her parental rights notwithstanding its finding that her mental health issues made it impossible for her to comply with the case plan; and (2) considering evidence outside of the record during the termination trial. Five permanency hearings were held between January 6, 2015 and December 15, 2015. Prior to the first permanency hearing, the Guardian ad litem again reported that while the Children were progressing, Doe was failing to comply with her case plan. Accordingly, it again recommended that the magistrate court move forward with the termination of Doe’s parental rights. IDHW’s report was substantially similar to its previous report; that is, Doe had continued her noncompliance with the case plan. Finding no reversible error in the magistrate court's judgment, the Idaho Supreme Court affirmed termination. View "Health & Welfare v. Jane Doe (2016-47)" on Justia Law