Justia Idaho Supreme Court Opinion Summaries

Scott Ostler was convicted of three counts of lewd conduct with a minor child under sixteen, and one count of sexual abuse of a child under the age of sixteen. This appeal related only to a single count of lewd conduct: Ostler claimed that the State violated his right to due process by adding an additional lewd conduct charge following a mistrial. The Court of Appeals vacated Ostler’s conviction for the additional felony, agreeing that the State violated Ostler’s right to due process. The Supreme Court affirmed the district court's judgment of conviction: "The proper avenue for Ostler to seek relief is in post-conviction proceedings." The Court ruled that Ostler “may still file a petition for post-conviction relief proceedings in order to ascertain whether defense counsel’s failure to object to the alleged error constituted ineffective assistance of counsel.” Ostler’s claim of prosecutorial vindictiveness required further factual development as to why the State added an additional lewd conduct charge. View "Idaho v. Ostler" on Justia Law

Appellant Miguel Cosio-Nava pled guilty in 2014 to the felony offense of domestic battery with traumatic injury, in violation of Idaho Code sections 18-903 and 18-918(2). Cosio was a Mexican citizen who had been in the United States since 1992 as a Legal Permanent Resident (“LPR”). At his sentencing hearing, the court discussed immigration issues with Cosio and his trial counsel. Cosio appealed the district court’s dismissal of his petition for post-conviction relief, in which he alleged that trial counsel provided him ineffective assistance by failing to advise him of the immigration consequences of pleading guilty. After review of the district court record, the Supreme Court found no error in the dismissal of Cosio's petition for relief and affirmed. View "Cosio-Nava v. Idaho" on Justia Law

The district court granted summary judgment dismissing the negligence, contract, and fraud claims brought by Path to Health, LLP (“Path”) against Daren Long and ALL-IN INC. d/b/a RE/MAX ALL-IN REALTORS (collectively “Realtors”). Path’s claims were based on the allegation that Long misrepresented that property Path purchased was zoned for commercial use when it was actually zoned for residential use. After review, the Supreme Court found that the district court erred in dismissing Path's breach of contract claim because Idaho Code section 54-2087 was incorporated into the Buyer Representation Agreement at issue in this case. Further, the Court found the district court erred in dismissing Path's fraud claim because it found issues of fact as to whether Path justifiably relied upon Long's representations. The Court reversed on those two issues, but affirmed as to all others. The case was remanded for further proceedings. View "Path to Health, LLP v. Long" on Justia Law

Counsel for appellant Martin Frantz hired attorney Merlyn Clark as an expert witness in an unrelated matter in 2009. Clark was a partner with respondent law firm Hawley Troxell Ennis & Hawley LLP (“Hawley Troxell”). In 2010, Frantz’ creditor, Idaho Independent Bank, hired Hawley Troxell to represent it in a contract action against Frantz. In 2011, while that matter was pending, Frantz filed for bankruptcy. Hawley Troxell continued to represent the Bank as a creditor in the bankruptcy, including in an adversary proceeding the Bank filed against Frantz in 2013. Frantz alleged in the adversary proceeding that Clark’s interactions with Frantz in the 2009 matter created an attorney-client relationship and that it was therefore a conflict of interest for Clark’s firm to represent the Bank against Frantz. Frantz also alleged that Hawley Troxell improperly used confidential information Clark acquired in the 2009 matter. The bankruptcy court concluded that there was no attorney-client relationship between Clark (or Hawley Troxell) and Frantz. The adversary proceeding was later dismissed as moot. Frantz subsequently sued Hawley Troxell in Idaho district court, alleging legal malpractice and breach of fiduciary duty. The district court denied pro hac vice admission to attorney Jeffrey Katz, Frantz’ chosen counsel. The district court also dismissed the complaint on the grounds of judicial estoppel, lack of standing, and abatement. Finally, it awarded Hawley Troxell attorney fees under Idaho Code sections 12-120(3) and 12-121. Frantz appealed the denial of pro hac vice admission, the dismissal of his complaint, and the award of attorney fees. Finding no reversible error after review of the trial court record, the Supreme Court affirmed. View "Frantz v. Troxell" on Justia Law

John Doe (Father) appealed a magistrate court’s order which modified the custody arrangement between Father and Jane Doe (Mother) that was outlined in the court’s Judgment and Order Modifying Prior Court Orders. Father argued that the magistrate court abused its discretion when it modified the custody schedule three separate times despite the fact that no evidentiary hearing was held and the court’s prior findings of fact and conclusions of law remained unchanged. Mother cross-appealed, arguing that the magistrate court erred as a matter of law in the findings of fact and conclusions of law it entered in relation to the Order Modifying Prior Court Orders. After review, the Supreme Court concluded the magistrate abused its discretion when it changes the initial custody arrangement, and therefore did not reach Father's other arguments on appeal. The Court reversed the magistrate court’s change of custody in its Order Modifying Prior Court Orders, and remanded this matter for further proceedings. View "Jane Doe I v. John Doe II" on Justia Law

Claimant-appellant Thomas Millard appealed the Idaho Industrial Commission’s (Commission) ruling that certain medical payments made by the Workers Compensation Fund of Utah on behalf of Millard were payable at the statutorily scheduled fee amounts rather than the full invoiced amounts. Millard argued that the Commission incorrectly applied the Idaho Supreme Court’s holding in "Neel v. Western Construction, Inc.," (206 P.3d 852 (2009)), by ruling that a surety may deny a claim then still be allowed to pay the medical fee schedule rate so long as the surety makes payment before the Commission issues a decision on compensability. Finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Millard v. ABCO Construction" on Justia Law

Marcelino Baeza appealed his conviction for one count of lewd conduct with a minor child under the age of sixteen involving his five-year-old niece, J.C. Baeza argued that allowing J.C. to testify at trial through closed-circuit television violated his due process right to a fair trial and presumption of innocence and that the district court failed to adequately consider the relative rights of the parties under Idaho Code section 9-1806 when it ordered the alternative method for presenting J.C.’s testimony. Finding no due process violation, the Supreme Court affirmed the conviction. View "Idaho v. Baeza" on Justia Law

John Doe and Mother were the natural parents of J.M, an eight-year-old boy. John Doe and Mother had what was described as a sporadic and volatile relationship for approximately ten years. During that time, both Doe and Mother used methamphetamine and other controlled substances and committed acts of domestic violence upon each other. Mother had three children; however, this appeal dealt only with the termination of Doe’s parental rights to J.M. Doe was J.M.'s biological son. Doe appealed the magistrate court’s judgment terminating his parental rights to J.M. The magistrate court determined that it was in J.M.’s best interests to terminate Doe’s parental rights under Idaho Code sections 16-2005(1)(b) and (d) because there was clear and convincing evidence that Doe had neglected J.M pursuant to Idaho Code section 16-2002(3)(b), and/or Doe would be unable to discharge his parental responsibilities for a prolonged indeterminate period of time, which would be injurious to J.M’s health, morals, or well-being. After review of the record, the Supreme Court found no abuse of discretion in the decision to terminate parental rights and affirmed. View "Re: Termination of Parental Rights (father)" on Justia Law

In 2010, Kandi Hall (“Kandi”) was looking for work, having been fired from her previous job as a paralegal. Emmett Corrigan (“Emmett”) was waiting to learn the results of the bar exam he had taken and wanted to hire a paralegal to work for him when he began practicing law. They were introduced by a mutual friend. Kandi and Emmett were immediately attracted to each other, and within two weeks they began having a sexual relationship. Emmett passed the bar exam, and he hired Kandi in November to work for him in the law office he had opened. Their relationship continued until March 11, 2012, when Kandi’s husband, Robert Dean Hall (“Rob”), shot and killed Emmett in the parking lot of a pharmacy. A jury found Rob guilty of murder in the second degree. Kandi testified at trial that she always loved her husband, never intended to leave him, and was committed to their marriage. She was the only witness to the events leading up to Emmett's shooting. The issue in this appeal of Rob's conviction on second-degree murder charges was whether the district court properly instructed the jury on the issue of self-defense (Rob himself had been shot in the confrontation with Emmett). After review of the district court record, the Idaho Supreme Court held that the district court did not err in its instruction and affirmed the judgment of conviction. View "Idaho v. Hall" on Justia Law

The issue in this appeal centered on whether a force majeure clause in a written contract between the county and a developer did not apply to the developer’s failure to obtain zoning approval in order to construct the cement plant required in the agreement. After review of the contract and the clause at issue here, the Supreme Court held that the clause was broad enough to apply. Accordingly, the Court vacated the district court's judgment and remanded this case for further proceedings. View "Burns Concrete, Inc v. Teton County" on Justia Law