Justia Idaho Supreme Court Opinion Summaries

The case involves Scott and Natalie Pinkham, who contracted with Three Peaks Homes, LLC, for the construction of a custom home. The construction did not go as planned and the contract was terminated before the home was completed. Three Peaks subsequently filed two $600,000 mechanics’ liens against the Pinkhams’ home. The Pinkhams then filed a complaint against David Plate, Rebeccah Jensen, Three Peaks, Rebel Crew Construction, LLC, and Legacy Management Enterprises, LLC, asserting several causes of action.The district court denied the Pinkhams’ motion for summary judgment. Later, the Pinkhams’ attorney, Lance Schuster, filed a motion to withdraw as counsel for Plate, Jensen, Three Peaks, and Legacy, which the court granted. The court ordered Appellants to appoint another attorney or appear in person within twenty-one days of service of the order, failing which, the court may enter default judgment against them. The court clerk served a copy of the withdrawal order on Appellants via first class mail.The Pinkhams moved for the entry of default and default judgment against Appellants and for dismissal of Appellants’ counterclaims with prejudice. The district court granted the Pinkhams’ motion without a hearing. Appellants later secured new counsel and filed a motion to set aside the default and default judgment under Idaho Rule of Civil Procedure 60(b)(1), (4), and (6). The district court denied Appellants’ motion.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision denying the motion to set aside the default and default judgment. The court held that the district court did not err in concluding that Appellants failed to demonstrate good cause to set aside the entry of default. The court also held that Appellants have failed to establish a right to relief under Rule 60(b). The court declined to award attorney fees on appeal. View "Pinkham v. Plate" on Justia Law

Martin Edmo Ish was convicted of voluntary manslaughter in 2017 and sentenced to 15 years, with 10 years fixed and five years indeterminate. However, his original conviction was later vacated by the Idaho Supreme Court in 2020. After the court's decision became final, Ish's bail was reinstated. Unable to post a bond, he was returned to jail to await his retrial. His second trial was postponed several times due to public safety concerns during the COVID-19 pandemic. Ish repeatedly moved for dismissal of his case citing speedy trial concerns, but his requests were denied. He also moved for a change of venue, which was also denied. His second trial commenced in July 2021, and he was again convicted of voluntary manslaughter. This time, he was sentenced to a fifteen-year unified sentence, with the first 14 years fixed and one year indeterminate, resulting in a fixed sentence four years longer than his original sentence. Ish appealed his conviction and sentence.The Idaho Supreme Court affirmed Ish's judgment of conviction and sentence. The court found that Ish's right to a speedy trial was not violated, as the delays were either neutral or justifiable. The court also found that the district court did not err in denying Ish's motion for a change of venue, as Ish failed to demonstrate that the jury pool was tainted by media coverage. The court further found that Ish did not demonstrate that a juror should have been excused for bias. The court also found that the district court did not err in imposing an unduly harsh sentence, and that the court did not err in denying Ish's Rule 35 motion for leniency following his second sentence. View "State v. Ish" on Justia Law

This case involves a dispute over water rights between James Whittaker and Whittaker Two Dot Ranch LLC (collectively "Whittaker") and Bruce and Glenda McConnell. The McConnells own seven water rights associated with their property adjacent to Lee Creek, which they historically diverted from two points: the Upper Diversion and the Lower Diversion. However, after a 2014 enforcement action by the Idaho Department of Water Resources (IDWR), the McConnells lost their ability to divert water via the Lower Diversion because they failed to claim it in the Snake River Basin Adjudication (SRBA). The McConnells subsequently filed an application to add the Lower Diversion as an authorized point of diversion to their seven water rights. Whittaker, the McConnells’ upstream neighbor, protested the application, fearing that the additional diversion point would injure his junior water rights.The IDWR hearing officer approved the McConnells’ application, determining that the transfer would not injure Whittaker’s water rights. The officer used the historic confluence of Stroud Creek and Porcupine Creek, located upstream of the Upper Diversion, for the injury analysis. Whittaker appealed to the Director of IDWR, who affirmed the hearing officer's decision. Whittaker then sought judicial review from the district court.The district court reversed the Director's decision, holding that the modern confluence, located downstream of the Upper Diversion, should be used for the injury analysis. The court found that the West Springs Ditch, which diverts water from Stroud Creek through Whittaker’s property, was an alteration of the stream flow and not an unauthorized diversion. The court concluded that approving the McConnells’ application would injure Whittaker’s water rights and held that the application could be approved subject to a condition subordinating the use of the McConnells’ Lower Diversion to Whittaker’s water right. The McConnells appealed to the Supreme Court of the State of Idaho.The Supreme Court reversed the district court's decision. The court held that the West Springs Ditch is a diversion, not an alteration, of Stroud Creek. The court also found that the West Springs Ditch is an unauthorized diversion because it was not claimed as a point of diversion in the SRBA. Therefore, the court concluded that the Director of IDWR correctly used the historic confluence for the injury analysis. The court held that the district court erred in using the modern confluence for the injury analysis and reversed the district court’s decision. View "Whittaker v. Idaho Department of Water Resources" on Justia Law

Benny Dean Campbell was detained by law enforcement while they were investigating a stolen motorcycle. During the detention, a police trooper discovered heroin and methamphetamine in Campbell's backpack. Campbell was charged with two felony counts for drug trafficking and possession of a controlled substance, and two misdemeanor counts for possession of a controlled substance and possession of drug paraphernalia. Campbell filed a motion to suppress the evidence, arguing that by initially placing him in handcuffs, the trooper converted his detention into an unlawful seizure under the Fourth Amendment to the United States Constitution.The district court agreed that Campbell’s detention was a de facto arrest; however, the court also determined that the evidence was admissible under the attenuation doctrine. After the court denied his motion, Campbell entered into a conditional plea agreement that preserved his right to appeal the denied motion. On appeal, he asked the Supreme Court of the State of Idaho to reject the federal attenuation doctrine because Article I, section 17 of the Idaho Constitution affords him greater protections than the federal standard and is incompatible with Idaho’s more expansive exclusionary rule.The Supreme Court of the State of Idaho affirmed the order of the district court. The court agreed with the district court’s conclusion that the State failed to establish that the use of handcuffs on Campbell was a reasonable precaution for the trooper’s safety. However, the court concluded that while the seizure of Campbell was unreasonable, the inevitable discovery exception to the Fourth Amendment makes suppression improper. The court found that even if handcuffs had never been used, the evidence would have been inevitably discovered whether the trooper had followed either parallel path once the trooper walked into the convenience store. Therefore, the court affirmed the district court’s order denying Campbell’s suppression motion on the alternate theory of inevitable discovery. View "State v. Campbell" on Justia Law

This case involves a dispute over a real estate and construction contract. The plaintiffs, Myles Davis and Janelle Dahl, sued their homebuilder, Blast Properties, Inc., and Tyler Bosier, alleging breach of contract, fraud, and violations of the Idaho Consumer Protection Act. The plaintiffs sought to amend their complaint to include a prayer for relief seeking punitive damages. The U.S. District Court granted the plaintiffs' motion to amend their complaint, but certified a question to the Supreme Court of the State of Idaho due to inconsistencies in the interpretation of Idaho Code section 6-1604(2), which prohibits claimants from including a prayer for relief seeking punitive damages in their initial pleading.The U.S. District Court asked the Supreme Court of the State of Idaho to determine the proper means a trial court must apply when considering a motion to amend a pleading to include a prayer for relief seeking punitive damages pursuant to Idaho Code section 6-1604(2). The Supreme Court of the State of Idaho rephrased the question to clarify the obligations of a trial court under Idaho Code section 6-1604(2) when ruling upon a motion to amend a complaint or counterclaim to include a prayer for relief seeking punitive damages.The Supreme Court of the State of Idaho held that section 6-1604(2) requires the trial court to conduct a careful examination of the evidence submitted by the moving party in support of its motion to amend and the arguments made to determine whether there is a "reasonable probability" that the evidence submitted is: (1) admissible at trial; and (2) "sufficient" to support an award of punitive damages. The word "sufficient" means that the claim giving rise to the request for punitive damages must be legally cognizable and the evidence presented must be substantial. The court clarified that the clear and convincing evidentiary standard is the standard for a jury, not the trial court when it is ruling on a motion to amend a pleading to include a prayer for relief seeking punitive damages. View "Davis v. Blast" on Justia Law

The case revolves around a workers' compensation claim filed by Christine Coray after she was injured at her workplace, Idaho Regional Hand & Upper Extremity Center. Following her injury, Coray's physician recommended back surgery. However, after an independent medical examination (IME) requested by her employer and its surety, they denied liability for the surgery and ongoing benefits, arguing that Coray had recovered from the workplace injury and that the surgery was necessitated by preexisting conditions. After undergoing surgery outside of the workers' compensation system, her employer requested a second IME by a different physician. Coray refused and sought a declaratory ruling from the Idaho Industrial Commission on whether the employer must use the same physician for multiple examinations of a single injury.The Idaho Industrial Commission ruled that the employer or surety is not required to use the same physician for multiple examinations of a single injury under Idaho Code section 72-433. However, it also held that each request for an IME is subject to a reasonableness standard, and the burden of proof for establishing reasonableness falls on the employer. Coray appealed this interpretation, while the employer cross-appealed the Commission's conclusion that it bears the burden of proving the reasonableness of a second IME.The Supreme Court of the State of Idaho affirmed the Idaho Industrial Commission's decision. It held that the plain language of Idaho Code section 72-433 does not prohibit an employer or surety from using different physicians to perform multiple examinations of a single injury. The court also affirmed the Commission's ruling that the employer bears the burden of establishing the reasonableness of its requested IME, including its choice of physician, if raised by the employee. View "Coray v. Idaho Regional Hand & Upper Extremity Center" on Justia Law

The case involves a dispute between Blaine Simmons, a landowner, and Tom Loertscher and Josh Williams, cattle owners. Simmons owns land in Bonneville County, Idaho, which is part of a herd district established in 1919. The herd district prohibits livestock from running at large within its boundaries. Loertscher owns Hi Willow Ranch Corporation, which has a permit to graze cattle on a portion of the Bureau of Land Management (BLM) land adjacent to Simmons' property. The BLM land is designated as open range, where livestock may graze and roam freely. Over time, cattle allegedly owned by Williams, grazing on the Loertscher Allotment, have strayed onto Simmons' property. Simmons repeatedly complained to Loertscher and Williams about this and set conditions for them to retrieve their cattle from his land.Simmons filed a small claims action against Loertscher and Williams alleging herd district violations and nuisance. The magistrate judge ruled in favor of Loertscher and Williams, stating that herd district laws do not apply to the Loertscher Allotment, which is on BLM land and designated as open range. The judge also stated that Loertscher and Williams have a common law right to enter Simmons’s Parcel at reasonable times and in a reasonable manner to retrieve their cattle. Simmons appealed this decision to the district court, which affirmed the magistrate court's decision.The Supreme Court of the State of Idaho affirmed the district court's decision. The court concluded that the district court's interpretation of Idaho Code section 25-2402, which excludes open range from any herd district and reinstates Idaho’s “fence-out” rule with respect to cattle straying from open range, was consistent with the history of herd district law and the effect of the 1963 amendment. The court also affirmed the district court's decision regarding the conditions governing the retrieval of cattle from Simmons’s Parcel. The court found that Simmons did not preserve this issue for appeal before the district court, and the issue was waived before this Court. View "Simmons v. Loertscher" on Justia Law

Dale Carter Shackelford was found guilty on six counts, including two counts of first-degree murder, and was sentenced to death for the murder counts and to various terms for the other counts, all to be served concurrently. However, the death sentences were vacated due to a Supreme Court decision, and the case was remanded for resentencing. At the resentencing hearing, Shackelford was given fixed life sentences for the murder counts to be served consecutively, but the court did not address the other counts. The written judgment stated that the murder sentences were to run consecutively with each other and with the sentences for the other counts.Shackelford, representing himself, filed a motion to correct a clerical error in the judgment, arguing that it did not accurately reflect the court's oral pronouncement of sentence because the court did not mention the other counts at the resentencing hearing. He contended that the judgment should be corrected to order that the consecutive sentences for the murder counts run concurrently with the sentences for the other counts. The district court denied Shackelford’s motion, ruling that the written judgment accurately reflected the oral pronouncement of sentence.On appeal, the Supreme Court of the State of Idaho reversed the district court's decision. The Supreme Court held that when there is a difference between the oral pronouncement of sentence and the written judgment, the oral pronouncement controls. The court found that the district court's oral pronouncement at Shackelford’s resentencing was unambiguous as far as the murder counts were concerned, but did not mention the other counts. Therefore, while the murder sentences run consecutively to each other, because the district court did not state that the other counts were to run consecutively to the murder counts, they will run concurrently with the murder counts. The case was remanded to the district court to correct the judgment to conform to the oral pronouncement of sentence. View "State v. Shackelford" on Justia Law

The case involves Jameel Fakhri Al Muthafar, who was convicted for aggravated assault and attempted strangulation. Al Muthafar argued that the district court erred by denying his motion to dismiss the information after the magistrate allowed hearsay statements at the preliminary hearing over his objection. The statements were made by a nurse during a dual medical and forensic examination. Al Muthafar contended that without these inadmissible statements, there was insufficient probable cause to bind the case over to the district court. He also argued that the district court abused its discretion in sentencing him to a unified sentence of fifteen years, with five years fixed.The district court denied Al Muthafar's motion to dismiss the commitment and information, arguing that the statements fell under the Rule 803(4) hearsay exception because the State failed to establish that the victim's statements were made for the purpose of medical treatment. The case proceeded to a jury trial where both the nurse and the victim testified. At the conclusion of the trial, the jury found Al Muthafar guilty of both aggravated assault and attempted strangulation. The district court subsequently sentenced Al Muthafar to fifteen years with the first five years fixed.The Supreme Court of the State of Idaho affirmed the district court's decision. The court held that while the magistrate court erred in admitting the nurse's testimony at the preliminary hearing, Al Muthafar's judgment of conviction should nevertheless be affirmed because he received a fair trial. The court also held that the district court did not abuse its discretion by imposing a unified term of fifteen years with five years fixed. View "State v. Al Muthafar" on Justia Law

The case involves an individual, referred to as "John Doe," who repeatedly applied for admission to the Idaho State Bar. Doe's applications were denied due to concerns about his character and fitness, including his honesty, judgment, and respect for the rights of others. Doe challenged these denials, arguing that his federal lawsuits against the Idaho State Bar were a necessary defense of his rights and that his conduct was protected by the First Amendment.The Idaho State Bar filed a petition with the Idaho Supreme Court, seeking permission to reject Doe's third application and to prohibit him from filing future applications for a specified period. Doe cross-petitioned, seeking immediate admission to the Idaho State Bar.The Idaho Supreme Court denied Doe's cross-petition, finding that he had not demonstrated that he met the essential eligibility requirements to practice law. The court granted the Idaho State Bar's petition in part, allowing it to reject Doe's third application and prohibiting Doe from filing a new application for two years. The court found that Doe had not shown a significant change in his circumstances that would render him eligible to practice law. The court also ordered the Idaho State Bar to refund Doe's application fee. View "ISB v. John Doe" on Justia Law