Justia Idaho Supreme Court Opinion Summaries

Respondent Kyle Rios was involved in a car accident in Lewiston. After the accident, Rios was arrested and taken to a nearby hospital by Officer Williams. At the hospital, Rios declined to sign a consent form for a blood draw. Without obtaining a warrant, Officer Williams directed hospital staff to draw Rios’ blood for a blood alcohol test. Rios did not verbally or physically resist. Based in part on the results of the blood alcohol test, Rios was charged with felony vehicular manslaughter and felony leaving the scene of the accident. Rios filed a motion to suppress the results of the blood alcohol test, alleging the results were obtained through an unlawful search and seizure. The district court granted Rios’ motion, concluding Rios withdrew implied consent to the blood draw by declining to sign the consent form. The State appealed. The Supreme Court reversed, finding that the State seemed to argue Rios renewed his consent by voluntarily presenting his arm to the phlebotomist and failing to verbally or physically resisting the blood draw. "These actions show only that Rios complied with the officer’s orders. Compliance with an officer’s orders alone does not renew consent." The Court held that Rios revoked implied consent by declining to sign the consent form, and therefore upheld the district court’s order suppressing the results of the blood alcohol test. View "Idaho v. Rios" on Justia Law

Defendant Brian Pratt was charged with two counts of delivery of a controlled substance and one count of trafficking in methamphetamine, all of which were felonies. He absconded after the first day of trial and was found guilty of all three counts in absentia. He was arrested about three months later. For each of the charges of delivery of a controlled substance (counts one and three), the district court sentenced him to the custody of the Idaho Board of Correction for five years, with two years fixed and the remaining three years indeterminate, and the court ordered that those sentences run concurrently. For the trafficking charge (count two), the court sentenced him to the custody of the board of correction for a period of twenty years, with the first ten years fixed and the remaining ten years indeterminate. The court ordered that this sentence be served consecutively to the sentences for counts one and three. Defendant appealed, challenging only the district court’s denial of his motion for a mistrial based upon a comment made by a prospective juror during voir dire. Finding that defendant passed the jury for cause at the end of the voir dire examination, he waived any objection to the jury panel. Therefore, the Supreme Court affirmed the judgment of the district court. View "Idaho v. Pratt" on Justia Law

Petitioner-appellant Shane Crawford petitioned for post-conviction relief after he was convicted for lewd conduct with a minor under the age of sixteen. Petitioner claimed he received ineffective assistance of counsel at both the trial and appellate stages. At the trial stage, Crawford claimed that his counsel was deficient in failing to request that the court either instruct the jury that manual-genital contact requires touching the vaginal area or define the term “genital.” Furthermore, he asserted that his trial counsel erred by failing to move for acquittal based upon insufficient evidence. On direct appeal of the conviction, Crawford’s counsel similarly did not raise a sufficiency of the evidence claim, which Crawford claimed constituted ineffective assistance of appellate counsel. The district court summarily dismissed Crawford’s petition, and he appealed. The Court of Appeals affirmed the summary dismissal. Crawford now seeks relief from this Court to have the summary dismissal of his claim reversed. Finding no reversible error in the summary dismissal of his claims, the Supreme Court affirmed. View "Crawford v. Idaho" on Justia Law

Brant Lee Eversole was arrested for driving while under the influence and, after refusing to submit to a breath alcohol test, was taken to a hospital where his blood was drawn. Based on the results of the blood test, police charged Eversole with felony DUI and Eversole entered a conditional guilty plea, preserving his right to appeal two orders, one of which was an order denying a suppression motion. In a 2-1 decision, the Court of Appeals vacated the order denying the motion to suppress on the basis that Eversole revoked implied consent to the blood draw when he refused to submit to the earlier breath test. The State petitioned the Supreme Court for review of the suppression issue only. Eversole additionally requested that the Supreme Court review the Court of Appeals’ decision affirming the district court’s denial of Eversole’s motion to dismiss. After review, the Supreme Court affirmed the district court’s denial of Eversole’s motion to dismiss. However, the Court reversed the district court’s denial of Eversole’s motion to suppress and remanded to the district court for further proceedings. View "Idaho v. Eversole" on Justia Law

Mary Pandrea appealed a district court decision regarding the partition of approximately twenty-three acres of real property owned jointly by Pandrea and her sister. Pandrea argued on appeal that the partition greatly prejudiced her and thus that the district court improperly partitioned the property in kind rather than by sale. She appealed several district court decisions denying motions she made for reconsideration and to amend her complaint. Finding no grounds to reversed any of the district court's decisions, the Supreme Court affirmed. View "Pandrea v. Barrett" on Justia Law

A magistrate court terminated Appellant Jane Doe’s (“Mother”) parental rights to her nine-year-old child (“Child”) for neglect. Mother argued on appeal of that termination: (1) the magistrate court’s finding of neglect is not supported by clear and convincing evidence; (2) the magistrate court should have rejected the Idaho Department of Health and Welfare’s (“IDHW”) petition to terminate parental rights because IDHW had failed to make reasonable efforts to reunify Mother and Child; (3) the magistrate court abused its discretion when it took judicial notice of findings from a prior proceeding; and (4) the magistrate court abused its discretion when it admitted evidence of IDHW’s efforts to determine whether the Indian Child Welfare Act applied to Child. Finding no reversible error, the Supreme Court affirmed. View "Idaho Department of Health & Welfare v. Jane Doe (2015-21)" on Justia Law

Before the Supreme Court in this case was an appeal of an Industrial Commission decision relating to the survivability of claims for permanent partial disability when a claimant died for reasons unrelated to the work accident. While receiving benefits based on his impairment rating, Keith Mayer died of a heart attack unrelated to his work accident. Mayer’s impairment rating was paid out in full following his death. However, Mayer died before a determination was made as to what permanent disability benefits he may have been entitled to in excess of his impairment rating. The parties submitted the issue on stipulated facts and the Industrial Commission concluded that permanent partial disability less than total survived the death of an injured worker when the death was unrelated to the work accident. The Industrial Commission also determined that the disability of the deceased worker should be evaluated as of the time immediately preceding the worker’s death. TPC Holdings, Inc. (TPC) appealed, arguing that Mayer’s claim for permanent partial disability did not survive death. Because the plain language of Idaho Code section 72-431 allowed for the survival of income benefits for workers who have suffered “permanent disability less than total,” the Supreme Court affirmed the Industrial Commission’s decision. View "Mayer v. TPC Holdings, Inc." on Justia Law

Claimant Amanda Wilson filed a complaint under the Worker’s Compensation Act to obtain benefits for a back injury that she alleged was caused or aggravated in the Spring of 2011. On February 15, 2008, Claimant had visited an emergency room in a hospital in Gilbert, Arizona, complaining that for one year she had back pain and right leg radiculopathy with a recent flare-up. On October 4, 2010, Claimant sought additional treatment for her low-back pain and right-leg sciatica at a health clinic in Twin Falls. On February 7, 2011, Claimant began working for Employer Conagra Foods Lamb Weston in Twin Falls. She had previously worked at Employer’s premises as an employee of a temp agency, performing general manual labor, including shoveling potatoes. On April 5, 2011, Claimant visited a nurse practitioner because of back pain. Claimant described bilateral sciatic pain radiating to her heel that had begun six months earlier. On April 6, 2011, Claimant sought medical care at a hospital emergency room in Twin Falls. She complained of increasing low-back pain over the prior three weeks, which initially started while shoveling potatoes while working for Employer. On April 8, 2011, Employer learned from the hospital and physician of Claimant’s trip to the emergency room regarding a work injury. Employer immediately suspended Claimant pending further investigation of whether she had violated its safety policies (to notify the Plant Manager of any injury, "regardless of how minor it may be at the time"). Employer contacted the emergency-room physician, and he was adamant that Claimant had reported to him that she was injured at work and that his notes so reflected. On April 13, 2011, Claimant visited another physician because of low-back pain and numbness in her legs. Employer terminated Claimant on April 18, 2011, for misconduct by failing to report an on-the-job injury in violation of the employee handbook. Claimant filed for unemployment compensation, but her claim was denied on the ground that her knowing violation of the policy constituted misconduct in connection with her employment. Claimant then applied for workers' compensation benefits. The matter was heard before a referee, who submitted proposed findings of fact, conclusions of law, and recommended order. The Industrial Commission declined to adopt the referee’s recommendation and issued its own findings of fact, conclusions of law, and order, finding that Claimant had failed to prove that she suffered an injury caused by an accident arising out of and in the course of her employment. Claimant appealed, but finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Wilson v. Conagra Foods Lamb Weston" on Justia Law

At issue before the Supreme Court in this matter was an action for declaratory relief related to planning and zoning in Canyon County. Appellant Coalition for Agriculture’s Future sued respondents Canyon County and the Canyon County Board of Commissioners (collectively “Canyon County”) under the Uniform Declaratory Judgment Act, seeking to invalidate Canyon County’s 2011 comprehensive plan and amendments thereto for noncompliance with Idaho’s Local Land Use Planning Act (LLUPA). The district court granted Canyon County’s motion to dismiss the action for lack of standing. The Coalition appealed. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Coalition for Agricultures's Future v. Canyon County" on Justia Law

Appellant Linda Kesting obtained a judgment against Respondent James Kesting for breach of an alimony/spousal support agreement entered into during their divorce. When that judgment was returned without recovery, the magistrate judge issued a Judgment of Qualified Domestic Relations Order (“QDRO”). The subsequent judgment was intended to allow recovery of the unpaid spousal support and associated attorney fees from James’ pension plan. James appealed to the district court, which reversed. The district court concluded that the QDRO was not valid because the spousal support agreement was not merged into the divorce decree and, therefore, the QDRO was not issued pursuant to the State’s domestic relations law as required under the Employee Retirement Income Security Act (“ERISA”). Linda appealed. The Supreme Court reversed, "disagree[ing] with the district court’s narrow view of domestic relations law. [...] The policies underlying ERISA’s anti-assignment provisions would not be furthered by allowing a person to avoid his or her support obligation because that obligation was agreed to between the parties. [...] Regardless of whether a support obligation was created by court order or provided for by agreement, it was not Congress’s intent that ERISA be used as a tool for a person to evade his or her familial support obligations." View "Kesting v. Kesting" on Justia Law