Justia Idaho Supreme Court Opinion Summaries

In early 2011, Trent Gearheart was severely injured in an automobile accident caused by an underinsured motorist (“UIM”). After the accident, Trent’s parents, Ronald Gearhart and Brandi L. McMahon, who were divorced, each attempted to collect on their separately held auto insurance policies with Enumclaw. Each of those policies provided maximum coverage of $300,000 for accidents caused by underinsured motorists. Enumclaw contended that because of anti-stacking language in the policies, the total UIM benefit under the combined policies was limited to $300,000. The district court held on summary judgment that the UIM anti-stacking provision in each policy was invalid and, therefore, ruled that Enumclaw was obligated for the full $300,000 policy limit on both policies. Enumclaw appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Gearhart v. Mutual of Enumclaw Ins Co" on Justia Law

A jury convicted Mark Lankford on two counts of felony murder for the 1983 murders of Robert and Cheryl Bravance, for which he received the death penalty. The United States Supreme Court overturned the sentence after it found that the State of Idaho failed to give notice that the death penalty could have been imposed in his case. Lankford was retried and again found guilty, and was sentenced to two life sentences. The district court denied Lankford’s first and second motions for new trial. Lankford timely appealed the denial of his motions for new trial. Lankford also filed a pro se Rule 35 motion for correction of an illegal sentence which the district court found to be untimely. Lankford argued to the Idaho Supreme Court that the district court erred in multiple ways and that he was entitled to another new trial. The State argued that Lankford failed to prove that reversible error was committed by the district court and that Lankford’s convictions should be affirmed. After review of the district court record, the Idaho Supreme Court concluded that the prosecutor in Lankford's case engaged in prosecutorial misconduct such that a new trial was warranted. Accordingly, the Supreme Court vacated the district court's judgment and remanded for a new trial. View "Idaho v. Lankford" on Justia Law

In 2006, John Doe (“Father”) and Mother were the parents of three minor daughters who were approximately 5, 6, and 7 years of age. A federal grand jury in Idaho issued an indictment charging Father with hiring someone from out of state to kill Mother. The indictment alleged that Father had agreed to pay that person $10,000. A jury found Father guilty, and the federal court sentenced him to 120 months in the custody of the United States Bureau of Prisons and three years of supervision following his release from prison. The federal court also sentenced him to a fine of $17,500. Following Father’s arrest and incarceration, Mother had sole custody of their three minor daughters. By 2013, the girls were 12, 13 and 14. Mother was having psychological issues and tried to take her own life; the eldest daughter also had attempted suicide. The State intervened and filed for protection under the Child Protective Act. The Department of Health and Welfare recommended the girls remain in shelter care due to an unstable home environment; Father wanted the girls placed with his adult son in Arizona. Ultimately, termination of Father's parental rights was recommended and granted. Father appealed, arguing the evidence of abandonment and neglect was insufficient to support termination of parental rights. Finding no reversible error in this respect, the Supreme Court affirmed the termination of Father's parental rights. View "Idaho Dept. of Health & Welfare v. John Doe (2016-09)" on Justia Law

On December 26, 2011, Mitchell Morrison arrived at the emergency department of St. Luke’s Regional Medical Center, Ltd. (“St. Luke’s”), in Meridian, complaining of chest pains. The emergency room doctor determined Mr. Morrison did not have a heart attack, but that he should consult with a cardiologist. On December 27, 2011, Barbara Morrison, Mr. Morrison’s wife, called for an appointment with the cardiologist, and the telephone was answered by a scheduler for St. Luke’s. The scheduler stated that the first available appointment for the cardiologist was in four weeks. Mrs. Morrison requested an earlier appointment, and she was given an appointment in three weeks with another St. Luke’s cardiologist. On January 11, 2012, Mr. Morrison died from a heart attack. On June 10, 2013, Mrs. Morrison, on her behalf and on behalf of her minor children, filed a wrongful death action against St. Luke’s, the emergency room doctor and the doctor's employer. Mrs. Morrison contended that St. Luke’s and the doctor's employer were liable based upon their own negligence and the imputed negligence of the doctor. St. Luke’s and the employer both filed motions for partial summary judgment seeking dismissal of the claims that they were negligent, and the district court granted those motions. The case was tried to a jury, which found that the emergency room doctor had not failed to meet the applicable standard of health care practice. Mrs. Morrison then timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Morrison v. St. Luke's RMC" on Justia Law

Plaintiff-appellant Barry Searcy was an inmate in the custody of the Idaho Department of Correction (IDOC). In 2011, he filed a civil complaint naming as defendants the Idaho State Board of Correction, IDOC, and various individual defendants in their official capacities (collectively “the Board”). Searcy’s complaint alleged that the Board illegally charged inmates fees for: (1) commissary goods; (2) telephone calls; (3) photocopying; (4) medical service co-pays; and (5) hobby supplies. The Legislature had not provided express statutory authorization for any of these fees at the time that Searcy brought this action. Instead, the fees were imposed based upon IDOC policy or Standard Operating Procedures (SOPs). The Board moved for summary judgment in all claims, and the district court ultimately granted the Board's motion. Searcy appealed, and his claims “solely challenging the district court’s grant of summary judgment as to Count I” (alleging that raising revenue through the disputed fees exceeded the Board’s rulemaking authority under Idaho Code section 20-212 and caused a wrongful forfeiture of property in violation of Idaho Code section 18-314) were heard by the Court of Appeals. In a split decision, the Court of Appeals affirmed. Searcy petitioned for review, which the Supreme Court granted. After review, the Court determined that the fees at issue here were not unconstitutional fees. As such, it affirmed the Court of Appeals' judgment. View "Searcy v. Idaho Bd of Correction" on Justia Law

In 2013, 44-year-old defendant Marcos Jimenez was at his girlfriend’s apartment after she had gone to work leaving him to care for her 17-year-old daughter, who had the mental capacity of a 10-year-old and a learning disability. Defendant had told the daughter that he would take her to town to buy her a computer, but first she had to take a shower. While she was doing so, he removed her clothing from the bathroom. When she emerged, he forced himself on the girl. Defendant was charged with sexual battery of a child seventeen years of age and rape. Pursuant to a plea bargain, he pled guilty to the sexual battery charge, and the State dismissed the rape charge. The court sentenced Defendant to eighteen years in the custody of the Idaho Board of Correction with three years fixed followed by an indeterminate period of fifteen years. The court also imposed a fine of $5,000 and a fine of $5,000 that is payable to the girl and her mother. Defendant was also required to register as a sex offender for the rest of his life. Defendant timely appealed. He contends that the court violated his Fifth Amendment rights because it drew adverse inferences from his refusal to submit to a psychosexual evaluation. Finding no violation of defendant's Fifth Amendment rights, the Idaho Supreme Court affirmed defendant's conviction and sentence. View "Idaho v. Jimenez" on Justia Law

In 2010, defendant William Dee Van Komen, Jr. was sentenced to five years in the custody of the Idaho Board of Correction, with the first two years fixed and the remaining three years indeterminate, for possession of marijuana with the intent to deliver. The court retained jurisdiction over the case for 180 days. Prior to the termination of the period of retained jurisdiction, the trial court had the discretion to suspend the sentence and place the defendant on probation. If the period of retained jurisdiction expired without the court affirmatively suspending the sentence and placing the defendant on probation, the court loses jurisdiction, and the defendant remains committed to the custody of the Board of Correction. In this case, the district court held a “rider-review” hearing to determine whether to suspend defendant’s sentence. The Department and the prosecutor recommended that defendant be placed on probation. The court agreed, and it suspended defendant’s sentence and placed him on probation for a period of five years. Defendant later admitted violating the terms of his probation, and in 2013, the court entered an order continuing defendant on probation with an additional term that he successfully complete a specified rehabilitation program. At the arraignment on the alleged probation violations, defendant admitted two, and a third alleged violation was withdrawn. The district court revoked defendant’s probation, but again retained jurisdiction, this time for 365 days. The court again held a rider-review in 2014, and at the conclusion, it was again recommended defendant be placed on probation. The district court then brought up the failure of Defendant to have a polygraph examination “to assess the truthfulness as to, one, no drugs or alcohol after March 28th, 2013, and the extent of sexual activity with [the sixteen-year-old girl].” Defense counsel told the court that he would advise Defendant to assert his Fifth Amendment rights with respect to his involvement with the girl because that could lead to additional charges. The court then ordered that it would relinquish jurisdiction and have Defendant serve the prison sentence because he had not had a polygraph test. The Court of Appeals, which affirmed the judgment of the district court on the ground that there was no Fifth Amendment violation because Defendant did not have a liberty interest in being placed on probation and the court’s refusal to place Defendant on probation did not extend the length of Defendant’s sentence. Finding that the trial court violated defendant's Fifth Amendment rights in using the refusal to take the polygraph test as grounds for its judgment, the Supreme Court vacated the district court's order and remanded for further proceedings. View "Idaho v. Van Komen, Jr." on Justia Law

Carol and Eric English appealed the dismissal of the their medical negligence claims against James Taylor, D.O., and Eastern Idaho Health Services, Inc., d/b/a Eastern Idaho Regional Medical Center (collectively, the Respondents). Carol English sustained stroke injuries after undergoing a medical procedure performed by Respondents. The Englishes subsequently filed a complaint alleging the Respondents were negligent in performing the procedure, which they alleged caused Carol’s injuries. The district court dismissed the Englishes’ claims on timeliness grounds. Finding that the district court correctly determined that the Englishes' second amended complaint naming Respondents was barred by the applicable statute of limitations for medical malpractice suits, the Supreme Court affirmed. View "English v. Taylor" on Justia Law

This appeal arose from a premises liability action brought against Walter Amundson, the owner of a piece of property in Kuna (the “Property”), by David Stiles, a social guest of one of Walter’s tenants. The district court dismissed the case on summary judgment, reasoning that: (1) Amundson had neither a general duty of care nor a duty to warn with respect to Stiles; and (2) although Amundson could be liable for any injury resulting from the negligent repair of the Property, Amundson's repair was not the proximate cause of Stiles’ injury. Finding no reversible error, the Supreme Court affirmed. View "Stiles v. Amundson" on Justia Law

Richard Wright was hired in 2006 by Ada County as the Public Information Officer. In 2008, Wright became the Director of Administrative Services, a position he held until 2009 when it was reclassified to Director of the Department of Administration in Ada County. That reclassification was the result of the Administrative Services being reorganized into the Department of Administration. This case came before the Idaho Supreme Court on appeal of a district court’s decision granting summary judgment to Ada County on Wright’s employment-related claims. After Wright was terminated from his employment with Ada County, he filed suit alleging, among other claims, that he was terminated in violation of the the Idaho Protection of Public Employees Act (the Whistleblower Act) and the Family Medical Leave Act (FMLA). Wright alleged that he was terminated in retaliation for the investigation he ordered into an employee who had been accused of workplace harassment. Alternatively, Wright alleged he was terminated in retaliation for his investigation into hostile work environment claims received from another Ada County employee. Wright amended his complaint to include negligent and intentional infliction of emotional distress claims. Ada County moved the district court for summary judgment on all claims, which the district court granted. Finding that the district court erred in granting summary judgment on Wright's Whistleblower and negligent infliction of emotional distress claims, the Supreme Court reversed. The Court affirmed the district court in all other respects and remanded this case for further proceedings. View "Wright v. Ada County" on Justia Law