Justia Idaho Supreme Court Opinion Summaries

Alik Takhsilov appealed the district court’s summary dismissal of his petition for post-conviction relief, arguing that his trial counsel was ineffective for failing to request a competency evaluation prior to his entry of guilty pleas. During the pendency of his underlying criminal case, Takhsilov was deemed incompetent to proceed and was transferred to Idaho State Hospital South pursuant to Idaho Code section 18-212. Three months later, he was found to have regained competency, and he was returned to the district court. Takhsilov then entered guilty pleas to one count of robbery under Idaho Code section 18-6501 and one count of burglary under Idaho Code section 18-1404. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Takhsilov v. Idaho" on Justia Law

Jonathan Hill was convicted for felony driving under the influence (DUI). He raised one issue on appeal. Over an unsuccessful hearsay objection, the deputy sheriff who conducted field sobriety tests (FSTs) of Hill was permitted to testify as to what he had been taught regarding the presence of vertical nystagmus. Hill’s appeal challenged that evidentiary ruling. The Supreme Court found that even if the testimony was relied upon for the basis of an expert opinion, it was improper to disclose the facts upon which Deputy Smith based his opinion. This error was not harmless, and as such, the Supreme Court vacated Hill's conviction and remanded the matter for a new trial. View "Idaho v. Hill" on Justia Law

Appellants Ronnel Barrett, Gregg Hammerberg, Eric Tester, and Matthew Williams were injured in a rock burst in 2011, and sued Hecla Mining Company, owner and operator of the Lucky Friday Mine. Appellants contended that Hecla knew the mine was unsafe and knowingly placed Appellants in danger of harm. Appellants claimed that such behavior constituted an act of “willful or unprovoked physical aggression” that was not exclusively covered by the Idaho Worker’s Compensation Act (IWCA). On cross motions for summary judgment, the district court ruled that because there was no evidence that Hecla specifically intended to harm Appellants, the claims were controlled exclusively by the IWCA. On that ground, the court granted summary judgment in favor of Hecla. On appeal, Appellants argued that the district court erred in its determination that the IWCA exclusively governed their claims. Finding no error, the Supreme Court affirmed. View "Barrett v. Hecla Mining Co" on Justia Law

Patricia Marek, individually and as personal representative of the Estate of Larry "Pete" Marek, and Pete's surviving children Michael, Jodie and Hayley, all appealed when the district court granted summary judgment in favor of Hecla Mining Company (and its related companies) and several former co-workers. The Mareks sued the company when Pete died after being injured in 2011 at a rock fall at the Lucky Friday Mine operated by Hecla. The Mareks argued that Hecla's decision to remove a pillar from the mining area was sufficiently egregious enough to allow them to pursue their claims outside of the Idaho Worker's Compensation Act. In its judgment in favor of Hecla, the district court concluded the Act applied because the company's conduct did not amount to "willful or unprovoked physical aggression," and claims were barred by the exclusivity provision of the Act. Finding no error in that analysis, the Supreme Court affirmed. View "Marek v. Hecla, Limited" on Justia Law

Appellant Dorothy McCarty appealed the grant of summary judgment holding that a quitclaim deed granting certain real property to McCarty was unenforceable as a matter of law because it did not contain an adequate description of the subject property. The issues raised on appeal were: (1) whether Idaho Code section 55-606 barred the grantors’ successors in interest from challenging the enforceability of the Quitclaim Deed that the grantors themselves executed; (2) whether the district court erred in striking evidence of the grantors’ intent at the time they executed the deed; (3) whether the district court erred in finding that the Quitclaim Deed did not contain an adequate description of the subject property; (4) whether the district court erred by holding that the grantors were thereafter prevented from transferring the property by an amendment to the trust documents; and (6) whether the district court erred in concluding that the doctrines of ‘reformation,’ ‘interlineation,’ and ‘correction deed’ were not applicable. Finding no reversible error, the Supreme Court affirmed. View "David & Marvel Benton Trust v. McCarty" on Justia Law

Defendant-appellant John Linze, Jr. appealed after he was convicted for conviction of possession of methamphetamine. On appeal, he argued the district court erred by refusing to suppress evidence obtained by police during a traffic stop. Specifically, Linze argued that: (1) the traffic stop was impermissibly extended in order to allow time for the drug detection dog to arrive; (2) the traffic stop was impermissibly extended in order to allow the drug detection dog to conduct a sweep; and (3) the alert of the drug detection dog was insufficient to establish probable cause to search the vehicle because the dog was unreliable. Linze’s initial appeal before the Court of Appeals resulted in his conviction being vacated. That court held that the time during which the drug detection dog conducted its sweep of the vehicle was an impermissible extension of the original traffic stop. The Supreme Court agreed with that reasoning and affirmed the appellate court. The district court’s judgment was vacated (as was the order of probation), and the order denying Linze’s motion to suppress was reversed. View "Idaho v. Linze" on Justia Law

CNW, LLC owned an office building in the Taylor’s Crossing business subdivision in Idaho Falls. In mid-June of 2012, a sinkhole developed under the parking lot of CNW’s building. It was later determined that the sinkhole was caused by water from Porter Canal infiltrating an abandoned sewer line and eroding the soil under the parking lot. Porter Canal was owned and operated by New Sweden Irrigation District (NSID); the abandoned sewer line was owned by the City of Idaho Falls (City). NSID denied responsibility for the sinkhole. CNW then served the City with a notice of tort claim. Shortly thereafter, NSID admitted that it had worked on the Porter Canal in the spring of 2012. Prior to that, NSID had repeatedly denied performing any work on the canal. CNW filed this lawsuit against NSID and the City on December 19, 2012. On January 25, 2013, CNW served NSID with an amended notice of tort claim. NSID moved for summary judgment on September 29, 2014. On December 31, 2014, the district court granted NSID’s motion for summary judgment. The district court found that CNW’s letter of October 18, 2012, was not sufficient to satisfy the requirements of the Idaho Tort Claims Act (ITCA). The district court also found that the 180 day time limit expired before CNW served the amended notice of tort claim in January. CNW filed a motion asking the district court to reconsider the grant of summary judgment. After a hearing, the district court denied the motion. CNW timely appealed. The Idaho Supreme Court reversed the trial court and remanded for further proceedings, finding that the district court erred in concluding one of the first notices of tort claim, delivered to NSID's secretary, satisfied the presentment requirement provided by the ITCA. View "CNW, LLC v. New Sweden Irrigation Dist." on Justia Law

Cesar Sepulveda appealed after a jury found him guilty of felony intimidating a witness, misdemeanor domestic battery, injury to a child, and two counts of attempted violation of a no contact order. Sepulveda contended that his right to confront witnesses, his right to present a defense, and his right to be free from double jeopardy were violated and that his convictions should have been vacated. Finding no such violations, the Supreme Court affirmed Sepulveda's convictions. View "Idaho v. Sepulveda" on Justia Law

Vernon Smith appeals the district court’s award of attorney fees to Treasure Valley Seed Company, LLC and its owner Don Tolmie (collectively TVSC). This case arose out of a contract for the sale of lima beans between Victoria H. Smith and TVSC. In 2013, Victoria’s son, Vernon, filed a complaint against TVSC alleging claims for breach of the lima beans contract. As plaintiff, the complaint named “VICTORIA H. SMITH, by and through her attorney in fact, Vernon K. Smith, by and through his Durable and Irrevocable Power of Attorney.” In 2014, TVSC learned Victoria had died on September 11, 2013—roughly three months before the complaint was filed. TVSC then moved to dismiss the complaint, contending there was no real party in interest. Vernon responded and argued he was the real party in interest because of his durable and irrevocable power of attorney. The district court concluded Vernon’s power of attorney had terminated at Victoria’s death. Further, the district court reasoned that because no personal representative had been appointed through probate, there was no real party in interest. Accordingly, the district court granted TVSC’s motion to dismiss. Vernon appealed. The Supreme Court found, after review of this matter: (1) there was indeed a real party in interest; and (2) the district court erred by assessing attorney fees jointly and severally against Victoria and Vernon. The matter was remanded for further proceedings. View "Smith v. Treasure Valley Seed Co." on Justia Law

Appellants DOT Compliance Service (“DOT Compliance”), Jeff Minert, David Minert, and Ryan Bunnell appealed a jury verdict finding that DOT Compliance and Bunnell tortiously interfered with Respondent Drug Testing Compliance Group, LLC’s (“DTC Group’s”) customer contracts and that Jeff and David Minert violated the covenant of good faith and fair dealing by disparaging DTC Group in violation of a settlement agreement entered into by the parties. DTC Group brought this suit alleging that DOT Compliance, through its owners and employees was calling DTC Group’s customers, asking them to cancel their service, and making disparaging comments about DTC Group. after careful consideration of the trial court record, the Supreme Court found that the trial court erred: (1) in denying Appellants' motion for a directed verdict on the tortious interference with contract claim; and (2) in denying Appellants' motion for JNOV on the breach of implied good faith and fair dealing claim against Jeff and David Minert. The trial court judgment was reversed and the matter remanded for further proceedings. View "Drug Testing Compliance Grp v. DOT Compliance Service" on Justia Law