Justia Idaho Supreme Court Opinion Summaries

In this case, Laurie Barton, a third-year law student at the University of Idaho, was accused of violating the university's honor code by committing academic misconduct during a final examination. Despite denying the allegations, she was sanctioned with degree denial after a series of Honor Court proceedings. Barton exhausted her administrative review options, including an appeal to the Idaho State Board of Education, and then petitioned for judicial review. The district court denied her petition. Instead of appealing this decision, Barton sued the Board of Regents of the University of Idaho and Idaho State Board of Education, alleging nine causes of action, all of which the district court dismissed at summary judgment.The district court's judgment was affirmed by the Supreme Court of the State of Idaho. The Supreme Court found that Barton had failed to raise a genuine issue of material fact that the University violated its duty of good faith and fair dealing or that it made a specific promise that induced her action. The court also found that Barton's motion for a protective order was implicitly denied and moot, as the case was resolved on summary judgment. The court concluded that Barton's appeal was pursued frivolously, unreasonably, and without foundation, and awarded attorney fees and costs to the University. View "Barton v. Board of Regents" on Justia Law

The defendant, Britian Lee Barr, was charged with eleven counts of sexual exploitation of a child for possessing child pornography. Barr had previously been convicted of felony possession of sexually exploitative material in 2011. On the second day of trial, Barr pleaded guilty to five counts of sexual exploitation of a child for possessing child pornography and admitted to being a repeat offender. In exchange for his guilty pleas, the other counts were dismissed. Barr was sentenced to five, fifteen-year fixed sentences to run consecutively, resulting in an aggregate seventy-five-year fixed sentence. The consecutive nature of the sentences was mandated by Idaho Code section 19-2520G(3).Barr appealed the sentence, arguing that the district court abused its discretion by failing to perceive that it had discretion to designate indeterminate portions for the mandatory fifteen-year sentences and that it had discretion to order the sentences be served concurrently. The Supreme Court of the State of Idaho affirmed the decision of the district court because Barr had not preserved his arguments for appeal. Barr returned to the district court and filed a Rule 35(a) motion to correct an illegal sentence. Barr argued that the consecutive sentence requirement in Idaho Code section 19-2520G(3) is unconstitutional because it violates the doctrine of separation of powers by usurping the judiciary’s inherent power to determine whether a sentence runs consecutively or concurrently. The district court denied the motion, concluding that the legislature is empowered to designate mandatory consecutive sentences under the plain language of Article V, section 13 of the Idaho Constitution. Barr timely appealed.The Supreme Court of the State of Idaho held that determining whether a sentence is to be served consecutively or concurrently is not a power reserved exclusively to the judiciary. As a result, section 19-2520G(3) does not violate the separation of powers provision of the Idaho Constitution. The court affirmed the district court's decision denying Barr's Rule 35(a) motion. View "State v. Barr" on Justia Law

In June 2016, Peter Franklin Goullette was driving with his child in the backseat when he struck and killed Kathy Stelzer and severely injured Zualita Updike, who were walking on the road. Goullette admitted to officers that he was attempting to buckle his son back in when he struck the victims. He was charged with vehicular manslaughter and reckless driving. Goullette entered a guilty plea while maintaining his innocence, known as an Alford plea. He later appealed his conviction, arguing that the district court abused its discretion when it accepted his guilty plea because it failed to inquire into the factual basis of his guilty plea.The case was first heard in the District Court of the First Judicial District of the State of Idaho, Bonner County, where Goullette was convicted. He then appealed to the Idaho Court of Appeals, which affirmed his conviction. Goullette subsequently filed a petition for review with the Supreme Court of the State of Idaho.The Supreme Court of the State of Idaho affirmed Goullette's conviction. The court held that the district court did not err in accepting Goullette’s Alford plea because the record as a whole demonstrated that Goullette entered a knowing, voluntary, and intelligent plea. The court also held that the district court did not err by failing to revisit the validity of Goullette’s plea at sentencing because the district court was not presented with evidence raising an obvious doubt as to Goullette’s guilt. View "State v. Goullette" on Justia Law

The case revolves around a dispute over a permit application to repair and maintain Imperial Gulch Road (IGR), which provides access to the property of the appellant, Jeffrey "Jae" Hill. The respondent, Blaine County, denied the permit application, concluding that it did not have the authority to issue the permit because it had previously declined to validate IGR. Hill filed a petition for judicial review of the Board’s decision.The district court affirmed the Board’s denial in part and vacated its decision in part. The court concluded that the Board did not validate IGR and therefore the Board lacked authority to issue the requested permit. However, the court remanded the matter back to the Board to determine if the Board had authority to issue the permit under a public easement theory. Hill appealed, arguing that the district court erred by determining that the Board had not validated IGR.The Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that the district court did not err when it affirmed the Board’s decision that it lacked authority to grant Hill’s permit because it had not validated IGR. The court found that Hill failed to establish that the Board’s decision denying his permit was arbitrary, capricious, or an abuse of discretion. The court did not disturb the district court’s order vacating the Board’s decision in part and remanding the matter to the Board for further proceedings. View "Hill v. Blaine County" on Justia Law

Michelle Oksman sued the City of Idaho Falls after slipping and falling on a wet surface in the lobby of the West Deist Aquatic Center, a facility owned and operated by the City. Oksman alleged negligence on the part of the City. The district court initially granted the City's motion for summary judgment, concluding that the City had no actual notice of a dangerous condition and did not fail to take reasonable action to remedy potential hazards. However, the court later withdrew its grant of summary judgment after Oksman identified the person who had allegedly stated that people frequently fell in the area where she had fallen. The case proceeded to a jury trial, during which the district court limited Oksman's testimony and declined to give a jury instruction Oksman requested regarding the reasonable value of necessary services. The jury returned a verdict in favor of the City, and the district court dismissed Oksman's complaint with prejudice. Oksman appealed.The Supreme Court of the State of Idaho vacated the district court's judgment and remanded the case for a new trial. The Supreme Court found that the district court had erred in limiting Oksman's testimony about a statement made by the manager of the aquatic center, which was crucial to Oksman's case. The Supreme Court also provided guidance on issues likely to arise again on remand, including the use of depositions for impeachment and the use of leading questions. The Supreme Court further vacated the district court's award of costs to the City as the prevailing party. Neither party was awarded attorney fees on appeal. View "Oksman v. City of Idaho Falls" on Justia Law

In July 2018, Heather Lee Hawking rented a room at a Super 8 hotel in Boise, Idaho, where she housed approximately fifty cats. Over five days, the cats caused extensive damage to the room. Hawking was subsequently charged with and convicted of misdemeanor malicious injury to property. After the incident, the hotel was sold to a new owner. Following Hawking's conviction, the magistrate court conducted an evidentiary hearing to determine restitution owed to the victim. Hawking appealed the Order for Restitution and Judgment.The magistrate court awarded the new owner of the Super 8 hotel $3,708.40 in restitution, reasoning that the new owner took the property in a damaged condition due to the real estate contract and "stepped into the shoes of the previous owners" through that contract. Hawking appealed this decision to the district court, which affirmed the magistrate court's order. Hawking then appealed to the Idaho Court of Appeals, which also affirmed the district court's decision. Hawking subsequently petitioned the Supreme Court of the State of Idaho for review.The Supreme Court of the State of Idaho reversed the district court's order affirming the magistrate court's restitution award. The court found that the State failed to establish that Super 8 was an entity or an assumed business name of a person or entity, and that Super 8 suffered economic loss or injury as a result of Hawking's criminal conduct. The court concluded that the State's failure to establish these elements was fatal to its restitution claim. The court remanded the case to the district court with instructions to vacate the Order for Restitution and Judgment and remand the matter to the magistrate court for further proceedings consistent with this opinion. View "State v. Hawking" on Justia Law

The case revolves around Jeffrey Marsalis's appeal for post-conviction relief based on claims of ineffective assistance of counsel. Marsalis was convicted of rape in 2009, a decision upheld by the Idaho Court of Appeals. He then filed a petition for post-conviction relief, alleging that his trial counsel was ineffective for failing to advise him of his 120-day speedy trial right under the Interstate Agreement on Detainers and for not hiring an expert witness to support his "blackout defense." The district court denied Marsalis's petition for post-conviction relief.The case was previously reviewed by the District Court of the Fifth Judicial District of the State of Idaho, Blaine County. The district court summarily dismissed Marsalis's petition after concluding that there was not a genuine issue of material fact regarding any of Marsalis's claims. Marsalis appealed the dismissal, and the Supreme Court of the State of Idaho affirmed in part and reversed in part. The Supreme Court concluded that the district court erred in summarily dismissing the claims that trial counsel was ineffective for failing to present an expert witness to discuss the scientific basis behind Marsalis's blackout defense, and for failing to inform Marsalis of his speedy trial rights under the Interstate Agreement on Detainers.In the Supreme Court of the State of Idaho, the court affirmed the district court's judgment. The court found that Marsalis failed to establish prejudice on his ineffective assistance of counsel claim concerning the Interstate Agreement on Detainers' 120-day speedy trial timeframe. The court also found that Marsalis failed to establish prejudice on his ineffective assistance of counsel claim concerning his trial counsel's failure to retain an expert witness. The court concluded that Marsalis failed to demonstrate a reasonable probability that the charges against him would have been dismissed with prejudice had trial counsel asserted his speedy trial rights at the December 1 hearing. The court also concluded that Marsalis failed to demonstrate a reasonable probability that, if an expert had provided some additional explanation concerning the scientific bases for blackouts, the jury would have found him not guilty. Therefore, the court affirmed the district court's dismissal of Marsalis's petition for post-conviction relief. View "Marsalis v. State" on Justia Law

The case revolves around a dispute over the ownership of funds in a joint checking account following the death of one of the parties named on the account. Karon “Kelly” Kelso was originally a joint owner of a checking account with his wife, Sandra Kelso. After Sandra's death, Linda Applington, a friend of Kelly’s, began helping Kelly process his monthly bills. Kelly later added Linda on his checking account as a joint owner with the right of survivorship. After Kelly's death, his son, Greg Kelso, became the personal representative and sole heir of Kelly’s estate. Greg sought to have the funds transferred to Kelly’s estate, but Linda claimed ownership of the account under the right of survivorship and declined to transfer the funds.The district court granted summary judgment in favor of Linda, finding clear and convincing evidence that Kelly intended Linda to have the funds in his account upon his death. Greg appealed to the Supreme Court of the State of Idaho.The Supreme Court of the State of Idaho reversed the district court’s grant of summary judgment and remanded for a jury trial. The court found that there were inconsistencies in the testimonies of Linda and Janet Overman, an employee of the bank, which raised questions about their credibility. The court held that summary judgment was not proper when the record raises any question as to the credibility of witnesses. The court also vacated the award of attorney fees to Linda, stating that the prevailing party has not been determined and fees may be considered at the conclusion of the case. View "Kelso v. Applington" on Justia Law

The case revolves around Cyrus Wolf Buehler, who was convicted for aggravated driving under the influence (DUI) after a collision with a motorized bicycle, resulting in severe injuries to the cyclist, Raymond Hanson. Buehler was found to have a blood alcohol concentration (BAC) of .181 and .179 at the time of the incident. He sought to introduce evidence suggesting that Hanson's conduct was a superseding, intervening cause of the collision, arguing that Hanson was speeding, under the influence, and his bicycle lacked a headlight. Buehler also challenged the admissibility of his BAC results, as the officer who administered the test had an expired certification.The District Court of the Sixth Judicial District of the State of Idaho denied Buehler's motions, ruling that the evidence he sought to introduce was irrelevant to the determination of whether his act of driving under the influence had some causal connection to Hanson’s injuries. The court also held that the officer’s lapsed certification did not require exclusion of Buehler's BAC results, as the State could establish the foundation for the admission of the evidence through expert testimony. Buehler's conviction was affirmed.On appeal, the Supreme Court of the State of Idaho upheld the lower court's decision. The Supreme Court held that Hanson's conduct was not relevant to the determination of whether Buehler's act of driving while under the influence had some causal connection to Hanson’s injuries. The court also affirmed the lower court's decision to admit Buehler's BAC results, ruling that the officer's lapsed certification did not affect the validity of the BAC results. The court concluded that the district court did not err in its rulings, and Buehler's judgment of conviction was affirmed. View "State v. Buehler" on Justia Law

This case involves a dispute between two neighboring landowners, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP), over real property and easement rights. Axelrod purchased a property in Teton County in 2003, which was not accessible by road. Michael Reid, who owned and operated an organic dairy farm on land owned by RLP, leased land adjacent to Axelrod's property. Axelrod built an access road through the RLP property, which led to a series of disputes between the parties. In 2017, Axelrod filed a lawsuit seeking clarification about his easement rights. The parties reached a settlement agreement, which required Axelrod to build a new road along a different easement and Reid to pay for the installation of a cattle guard. However, disagreements arose over the placement and cost of the cattle guard, leading to further litigation.The district court granted Axelrod's motion for summary judgment, concluding that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The court also found that Reid had breached the settlement agreement by failing to pay for the cattle guard. Reid appealed the decision.The Supreme Court of the State of Idaho affirmed the district court's decision in part and vacated it in part. The court affirmed the grant of summary judgment against Reid and the dismissal of RLP's counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The court also affirmed the judgment on Axelrod's breach of contract claim and the refusal to allow amendment of the pleadings to add Reid Family Limited Partnership as a party. However, the court vacated the dismissal of RLP's trespass claim and the award of attorney fees to Axelrod against RLP, remanding for further proceedings. View "Axelrod v. Reid Limited Partnership" on Justia Law