Justia Idaho Supreme Court Opinion Summaries

The faulty, inadequate, or defective work exclusion did not apply to the loss in this case. At issue in this appeal was the dismissal of Plaintiff’s action seeking to recover under an insurance policy for the loss of her house caused when a renter, who had an option to purchase the house, demolished it. The district court held that coverage for such loss was excluded under the policy. The Supreme Court vacated the judgment of the district court and remanded this case for further proceedings. View "Fisher v. Garrison Property & Casualty Ins" on Justia Law

Jesse Mann appealed his conviction for trafficking marijuana, driving without privileges, and possession of drug paraphernalia which were entered after a jury found him guilty of the charges. Prior to trial, Mann sought suppression of the evidence related to the marijuana and paraphernalia charges. The district court found that Mann did not have standing to challenge the search as the evidence was found in a rental car which he was not authorized to drive. Mann argued that he had a reasonable expectation of privacy in the rental car because he had permission from the lessee to drive the car. Mann also argued that the jury instruction regarding the paraphernalia charge was erroneous. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Mann" on Justia Law

The Idaho Supreme Court concluded the district court did not err in dismissing the State Defendants under the Constitutionally Based Educational Claims Act (“CBECA”). This appeal arose from Russell Joki’s action challenging the constitutionality of: (1) fees charged to students of Meridian Joint District #21 ; and (2) the statewide system of funding Idaho’s public schools. Joki and sixteen other individuals (collectively referred to as “Joki”) initiated the suit against the State, the Idaho Legislature, the Idaho State Board of Education, and the Superintendent of Public Instruction (collectively referred to as the “State Defendants”), all 114 Idaho public school districts, and one charter school. The district court granted the State Defendants’ motion to dismiss. Joki argued the CBECA did not apply here, but the Supreme Court disagreed, finding: (1) the CBECA was constitutional, “it is not unreasonable for the legislature to also declare that allegations that the required educational services are not being furnished should first be addressed to the local school districts which have been given the responsibility and authority to provide those services;” and (2) Joki’s claims relating to the fees levied by the school districts fell squarely within the definition of a constitutionally based educational claim because the legislature’s duty was to provide free common schools. View "Joki v. Idaho Bd of Education" on Justia Law

The State appealed the district court’s order suppressing evidence against Victor Garcia-Rodriguez. In 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. This stop ultimately led to Garcia-Rodriguez’s arrest. A search incident to arrest uncovered methamphetamine on his person, and 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 State argued that the district court erred by suppressing the evidence because the stop was justified by reasonable suspicion, the arrest was justified by probable cause, and the search of Garcia-Rodriguez’s person was proper as a search incident to arrest. Because the Idaho Supreme Court decided this case on the issue of probable cause for the arrest and the subsequent search incident to arrest, it did not consider the issue of the initial stop. State consistently argued that Garcia-Rodriguez was arrested pursuant to Idaho Code section 49-301(1) for driving without a license and that the arresting officer reasonably concluded that Garcia-Rodriguez “would likely not appear in court, justifying [Garcia-Rodriguez’s] arrest pursuant to Idaho Code 49-301 and 49-1407(1).” That position was set forth in the State’s Affidavit in Support of Complaint or Warrant for Arrest, the State’s Memorandum Opposing Defendant’s Motion to Suppress under the heading “Basis for the Arrest,” and in the State’s Response to Defendant’s Reply to State’s Opposition to Defendant’s Motion to Suppress, once again under the heading “Basis for the Arrest.” The State’s current argument that Idaho Code section 49-1407 was immaterial to the question of the constitutionality of the arrest was nowhere to be found. As such, the State’s argument that the arrest and search incident to arrest were constitutional based on probable cause regardless of state law statutory limitations was not properly before the Supreme Court. The State therefore waived its argument that Garcia-Rodriguez's arrest was justified pursuant to 49-1407(1). The Court therefore affirmed the district court. View "Idaho v. Garcia-Rodriguez" on Justia Law

Val and LaRee Westover appealed the district court’s judgment and denial of their request for writs of mandate and prohibition against Franklin County Assessor Jase Cundick. The dispute arose when the Westovers granted an easement to Rocky Mountain Power on property owned by the Westovers. Based on his office’s records, Cundick sent a letter to Rocky Mountain Power stating that the Westovers did not own the property in question. The Westovers sought a writ of mandate to require Cundick to retract the letter and a writ of prohibition to prevent him from sending such letters in the future. The district court denied the Westovers’ request for writs of mandate and prohibition after it concluded that there were other remedies available at law. On appeal, the Westovers argued the district court erred by failing to grant injunctive relief prohibiting Cundick from sending out letters concerning real estate transactions and property ownership. Although the Westovers’ complaint did not request that the district court grant injunctive relief, they argued that the district court erred because the Westovers were clearly entitled to injunctive relief under Idaho Rule of Civil Procedure 54(c). Finding no reversible error, the Supreme Court affirmed. View "Westover v. Cundick" on Justia Law

In May 2012, James Daly was charged with six felony counts of Lewd and Lascivious Conduct with a Minor Under Sixteen. Pursuant to a plea agreement, Daly pleaded guilty to one count. At the start of the sentencing hearing, Daly moved to substitute counsel. The district court denied the motion. Daly then moved to continue the hearing, so that new counsel could be present for sentencing. The district court also denied this motion, indicating “[w]e have already continued the sentencing in this case for a month to get an additional mental health evaluation, and I don’t think that would be a sensible course of action.” The district court then sentenced Daly to twenty years, with three years fixed, and retained jurisdiction. Daly appealed. The Court of Appeals reviewed the case and held that: (1) it had jurisdiction over Daly’s claims under the nunc pro tunc judgment because it related back to the original judgment and enabled Daly to appeal any issues in the original judgment; and (2) Daly did not receive the “full and fair” hearing he should have received on his motion to substitute counsel. Accordingly, the Court of Appeals remanded for a hearing on the motion to substitute counsel and the motion for a continuance. The State petitioned the Idaho Supreme Court for review of the Court of Appeals decision, specifically on the question of whether the duty to inquire into the reasons for requesting substitute counsel applies to retained counsel. The Supreme Court granted the State’s petition for review. Thereafter, Daly moved to dismiss his appeal and vacate the Court of Appeals decision because he had been granted parole. The State concurred in the motion, provided the Court of Appeals decision was vacated in the dismissal. The Supreme Court reviewed this matter on the issue of whether the district court erred in denying Daly’s motion to substitute counsel and to continue the sentencing hearing so he could retain different counsel. After review, the Supreme Court found no reversible error in the district court’s judgment, and affirmed Daly’s conviction and sentence. View "Idaho v. Daly" on Justia Law

Enrique Lopez appeals an order of the Idaho Industrial Commission (“Industrial Commission”) declining to award him additional workman’s compensation income benefits for binaural hearing loss he sustained as a result of a workplace accident. Lopez was injured by a bull while working on a dairy. Lopez complained to the Industrial Commission that he was entitled to additional income benefits based on his interpretation of the statutory schedule for permanent impairments in Idaho Code section 72-428. The Industrial Commission disagreed, holding that Lopez was only entitled to the 8% impairment benefits previously paid. Lopez timely appealed. Finding no error in the Commission’s calculation of Lopez’ income benefits for his partial binaural hearing loss, the Supreme Court affirmed. View "Lopez v. Vanbeek Herd Partnership" on Justia Law

In November 2013, Christina Wisdom pled guilty to one count of injury to a child. That plea was based on Wisdom allowing her husband, Ronald Wisdom, to access Wisdom’s daughter, M.L., who was born in a prior marriage, despite knowing that Ronald had previously sexually abused M.L. This appeal centered on a restitution award the district court entered under Idaho Code section 19-5304. The award required Wisdom to pay $11,069.82 for counseling services for the victim of her crime. Wisdom appealed the award to the Idaho Court of Appeals, which vacated the award for lack of causation. The Supreme Court granted the State’s petition for review, and affirmed the district court. View "Idaho v. Wisdom" on Justia Law

In 2014, seventeen-year-old plaintiff Seth Griffith was seriously injured when he attempted a triple front flip into a pit filled with foam blocks at an indoor trampoline park owned and operated by JumpTime Meridian, LLC (“JumpTime”). Plaintiff’s girlfriend and her sister were near the large foam pit. Plaintiff jumped into the large foam pit a few times. He spent about 45 minutes “kind of horsing around on both the runway trampoline and the foam pit and the twin trampolines.” After he did a double front flip into the small foam pit, the monitor came up to him and asked if he had ever done a double before. He answered that he had. As he continued performing double front flips into the small foam pit, he decided to try a triple front flip. When he attempted it, he did not rotate far enough and landed on his head and neck, suffering a cervical dislocation and fracture, which required a fusion of his C6 and C7 vertebrae. Plaintiff filed this action alleging that JumpTime negligently caused his injury. He contended that because he was under the age of eighteen, JumpTime had a duty to supervise him. He had been intentionally landing the double front flips on his back in the pit. He testified that he did so “because you don’t want to land on your feet because you can bash your head against your knees.” JumpTime’s written policy manual instructed its employees with respect to the foam pit to “[f]ollow the rules outlined on the wall and continuously enforce it.” There were signs on the walls near the two pits that instructed customers to land on their feet. JumpTime moved for summary judgment alleging that there was no negligence, based upon the opinion of an expert that industry standards permitted landing a front flip into a foam pit on one’s feet, buttocks, or back, and that there was no evidence of causation. In response, Plaintiff contended that the signs on the wall stating how to land in the foam pit established the standard of care and that because of the attendant’s failure to admonish him for landing incorrectly, he was not discouraged from attempting a more difficult maneuver like a triple front flip. The district court granted JumpTime’s motion for summary judgment, holding that Plaintiff had failed to produce evidence of negligence and causation. Plaintiff then timely appealed. Finding that Plaintiff’s testimony did not support an inference that JumpTime was in any way responsible for his decision to try the triple front flip, the district court did not err in granting summary judgment to JumpTime based upon the lack of evidence regarding causation. View "Griffith v. JumpTime Meridian, LLC" on Justia Law

Defendant Patrick Bailey pled guilty to one count of lewd conduct with a minor under sixteen years of age. The alleged victim his ten-year-old daughter, who was “so severely impaired by autism that she could not speak a full sentence or describe anything that had happened to her.” Defendant contended that the district court abused its discretion in imposing his life sentence. Finding no such abuse of discretion, the Supreme Court affirmed defendant’s conviction and sentence. View "Idaho v. Bailey" on Justia Law