Justia Idaho Supreme Court Opinion Summaries

In 1992, Todd Rich was indicted for felony rape, allegedly committed between November 1991 and January 1992; he pled guilty on August 19, 1992; and on October 23, 1992, the district court sentenced him to six years in the custody of the Idaho Board of Correction. The district court retained jurisdiction for 120 days, and ultimately suspended the remainder of Rich’s sentence and placed him on probation. Rich successfully completed his probation on or about March 2, 2004. The following day, Rich filed a motion asking the district court in his criminal case for relief pursuant to Idaho Code section 19-2604(2), which was granted. The district court reduced Rich’s charge to a misdemeanor. The order reducing the charge stated that “the Judgment is hereby deemed a misdemeanor conviction, thereby restoring [Rich] to his civil rights.” At some point, Rich moved to Pennsylvania. He apparently applied for permission to possess a firearm in Pennsylvania. His request was denied by an administrative law judge who ordered: “It appearing that under Idaho law, I.C. 18-310(2), final discharge for a conviction of rape does not restore the right to ship, transport, possess or receive a firearm, the determination of the Pennsylvania State Police that Todd Rich is prohibited under the Uniform Firearms Act, 18 Pa. C.S. 6101 et seq., is upheld.” Rich filed this action seeking a declaratory judgment that he “may lawfully purchase, own, possess or have under his custody or control a firearm under the laws of the State of Idaho.” The State responded by contending that Rich had no standing to seek such relief. The district court dismissed the case on two alternative grounds: (1) Rich did not have standing because no real, substantial, and concrete controversy then existed; and (2) “Idaho Code 18-310(3) provides the mechanism for the restoration of civil rights is through application to the commission of pardons and parole, not through the District Court.” The district court entered a judgment dismissing this action with prejudice. Finding no reversible error, the Idaho Supreme Court affirmed. View "Rich v. Idaho" on Justia Law

In 2013, claimant Scott Chadwick filed a complaint with the Industrial Commission seeking benefits under the Worker’s Compensation Law from his employer, Multi-State Electric, LLC, and its surety, Idaho State Insurance Fund. Claimant alleged that he had suffered back injuries as a result of two separate accidents at work in 2012. The matter was tried to a referee, but the Commission did not adopt the referee’s recommendations. After considering the Claimant’s prehearing deposition, the testimony presented during the evidentiary hearing before the referee, and the exhibits, the Commission issued its findings of fact, conclusions of law, and order. The Commission found that Claimant failed to prove that he suffered an injury from a workplace accident in a May event and that he failed to prove that a July event occurred. The Commission alternatively found that he had failed to provide timely notice to his employer of both claimed accidents, and that he failed to prove that Employer was not prejudiced by the failure to give timely notice. Therefore, he was denied benefits. Claimant then timely appealed. Finding no reversible error, the Supreme Court affirmed the Commission. View "Chadwick v. Multi-State Electric, LLC" on Justia Law

The minor at issue here, H.T., was the child of John Doe II and Jane Doe. John Doe II and Jane Doe were married around March of 2002 and were divorced early the following summer. H.T. was born in 2002. John Doe II was incarcerated in 2003, when H.T. was about sixteen months old. John Doe II would be eligible for parole in December, 2028. In 2005, Jane Doe met John Doe I. They married in 2008. John Doe I was employed by the United States Air Force and has been with the Air Force for the past eighteen years. Jane Doe also served in the Air Force. H.T. resided with John Doe I and Jane Doe, who were stationed overseas. John Doe II appealed the termination of his parental rights to H.T. The magistrate court terminated John Doe II’s parental rights and allowed John Doe I to adopt H.T. John Doe II argued that John Doe I lacked standing to petition for termination of his parental rights and the magistrate court’s decisions were not supported by clear and convincing evidence. “The fundamental divergence between the trial court’s oral pronouncement and written decision require us to vacate the order terminating John Doe II’s parental rights. Our decision today is not intended to suggest that there is no basis for terminating John Doe II’s parental rights or that John Doe I should not be permitted to adopt H.T. Instead, this decision is entirely driven by a fundamental failure by the trial judge to fulfill his duties in such a case.” The Supreme Court vacated the judgment of the magistrate court and remanded for the magistrate to prepare new findings of fact and conclusions of law. View "John Doe I v. John Doe II" on Justia Law

Defendant-appellant Jorge Lopez-Orozco was convicted by jury on three counts of first degree murder. The district imposed three concurrent determinate life sentences. Defendant appealed, arguing: (1) the district court erred in finding that his brother was unavailable as a witness at trial and allowing the brother’s preliminary hearing testimony to be read into evidence; and (2) the court erred in allowing the brother’s unsworn written statement to law enforcement to also be read into evidence. Finding neither of these contentions to warrant reversal of defendant’s convictions, the Supreme Court affirmed. View "Idaho v. Lopez-Orozco" on Justia Law

Shortly before midnight on November 14, 2012, Boise Police Officer Ryan Thueson began following Nathan David Neal in a patrol car. Thueson observed Neal drive his pickup onto, but not across, the line at the edge of the roadway (the “fog line”). Thueson continued to follow Neal until, about one mile further west, he saw Neal again drive onto, but not across, the line at the edge of the roadway. According to Officer Thueson’s original report, at the time he observed Neal drive onto the fog line twice. Thueson learned later that there was no fog line and the line actually marked a bicycle lane. Thueson stopped Neal after he turned right. This traffic stop led to Neal’s arrest for driving under the influence of alcohol. He was not ticketed for any traffic violations. Neal moved to suppress, claiming the officer lacked reasonable articulable suspicion of criminal activity to justify a traffic stop. The State argued the officer observed both a misdemeanor (Boise City Code section 10-10-17, which prohibited driving on a bicycle lane) and an infraction (Idaho Code section 49-637, which required drivers to maintain a single lane of travel), and that these observations justified the stop. The State also argued that observing these two instances of driving onto the line on the right, close to midnight, gave the officer reasonable suspicion that the driver was intoxicated, which also justified the stop. After a hearing and reviewing briefs, the magistrate granted Neal’s motion to suppress. The magistrate held there was no traffic violation justifying the stop because Neal did not cross the line and enter another lane. The magistrate also held that driving onto an alleged fog line two times did not create a driving pattern outside the broad range of normal driving behavior, so the officer did not have reasonable suspicion of DUI. Finally, the magistrate found there was no evidence the officer’s observations occurred in Boise, so there was no violation of Boise City Code. The State appealed, and the district court reversed, ultimately concluding that the officer had reasonable suspicion that both “the statute and ordinance were violated by Mr. Neal’s driving upon the fog line and upon the bike lane marker.” Neal appealed, and the Court of Appeals affirmed, ruling that driving on, but not across, an alleged fog line on the roadway violated the state statute requirement that a vehicle remain within its lane. The Supreme Court granted Neal’s petition for review, and held that driving onto but not across the line marking the right edge of the road did not violate Idaho Code section 49-637. Therefore the officer’s stop of Neal was not justified. The Supreme Court reversed the decision of the district court reversing the magistrate’s granting of Neal’s motion to suppress. View "Idaho v. Neal" on Justia Law

This dispute related to a strip of land that was part of a cell tower site located in the City of Coeur d’Alene. Sherman Storage, LLC sued Global Signal Acquisitions II, LLC seeking to eject Global from that strip of land, and seeking contract damages and mesne profits. Sherman appealed the district court’s judgment in Global’s favor and its order that Sherman pay a substantial sum for Global’s attorney fees. Finding no reversible error after a review of the district court record, the Supreme Court affirmed. View "Sherman Storage v. Global Signal Acq." on Justia Law

Claimant Barbara Kelly was an employee of Blue Ribbon Linen Supply, Inc. when a cart rolled over her left foot. She filed for workers’ compensation benefits. Kelly sustained additional injuries in an automobile accident when returning home from an Independent Medical Evaluation (IME) scheduled by the Idaho State Insurance Fund (Surety) in connection with the cart incident. The Industrial Commission concluded that Kelly’s injuries from the automobile accident were not compensable because they did not arise out of and in the course of her employment with Blue Ribbon. The Supreme Court concluded after review that the causal connection between Kelly’s employment and the injuries she sustained as a result of the accident was sufficiently compelling that it held that the injuries arose out of and in the course of her employment. Accordingly, the Court reversed the Commission’s decision and remanded for further proceedings. View "Kelly v. Blue Ribbon Linen Supply, Inc." on Justia Law

This case was the sixth appeal considered by the Idaho Supreme Court following petitioner-appellant Timothy Dunlap’s guilty plea to first-degree murder. The district court summarily dismissed Dunlap’s successive petition for post-conviction relief. Dunlap raised several substantive claims for post-conviction relief. For each claim, he advanced a corresponding claim of ineffective assistance of appellate counsel. After review and finding no reversible error, the Supreme Court affirmed the district court’s summary dismissal of Dunlap’s successive petition for post-conviction relief. View "Dunlap v. Idaho" on Justia Law

Appellant, the Greater Boise Auditorium District, filed a petition for judicial confirmation (pursuant to Idaho Code section 7-1304) asking the district court for a determination that a lease the District intended to enter into did not violate the Constitution’s Article VIII, section 3 clause prohibiting a municipal body, without voter approval, from incurring indebtedness or liabilities greater than it has funds to pay for in the fiscal year. Respondent, Boise resident and property owner David Frazier, objected to the requested judicial confirmation, and appeared in the case to contest it. The district court denied the Petition for Judicial Confirmation and the District appealed. Frazier sought attorneys’ fees on appeal. After review, the Supreme Court reversed the district court’s denial of the District’s request for judicial confirmation and held that the agreements into which it entered satisfied Article VIII, section 3 of the Constitution. View "Greater Boise Auditorium District v. Frazier" on Justia Law

In prior proceedings, the Idaho Supreme Court reversed the district court’s judgment in favor of The Golf Club at Black Rock (Golf Club) and its award of costs and attorney fees. This case was an appeal of the district court’s denial, upon remand, of Appellant’s Memorandum of Attorney Fees and Costs. Appellant argued that the district court erred in ruling that the court did not have jurisdiction to award fees and costs on remand. The Supreme Court agreed with appellant and reversed. View "Sky Canyon Properties v. The Golf Club at Black Rock, LLC" on Justia Law