Justia Idaho Supreme Court Opinion Summaries

This case involves a dispute over a real estate and construction contract. The plaintiffs, Myles Davis and Janelle Dahl, sued their homebuilder, Blast Properties, Inc., and Tyler Bosier, alleging breach of contract, fraud, and violations of the Idaho Consumer Protection Act. The plaintiffs sought to amend their complaint to include a prayer for relief seeking punitive damages. The U.S. District Court granted the plaintiffs' motion to amend their complaint, but certified a question to the Supreme Court of the State of Idaho due to inconsistencies in the interpretation of Idaho Code section 6-1604(2), which prohibits claimants from including a prayer for relief seeking punitive damages in their initial pleading.The U.S. District Court asked the Supreme Court of the State of Idaho to determine the proper means a trial court must apply when considering a motion to amend a pleading to include a prayer for relief seeking punitive damages pursuant to Idaho Code section 6-1604(2). The Supreme Court of the State of Idaho rephrased the question to clarify the obligations of a trial court under Idaho Code section 6-1604(2) when ruling upon a motion to amend a complaint or counterclaim to include a prayer for relief seeking punitive damages.The Supreme Court of the State of Idaho held that section 6-1604(2) requires the trial court to conduct a careful examination of the evidence submitted by the moving party in support of its motion to amend and the arguments made to determine whether there is a "reasonable probability" that the evidence submitted is: (1) admissible at trial; and (2) "sufficient" to support an award of punitive damages. The word "sufficient" means that the claim giving rise to the request for punitive damages must be legally cognizable and the evidence presented must be substantial. The court clarified that the clear and convincing evidentiary standard is the standard for a jury, not the trial court when it is ruling on a motion to amend a pleading to include a prayer for relief seeking punitive damages. View "Davis v. Blast" on Justia Law

The case revolves around a workers' compensation claim filed by Christine Coray after she was injured at her workplace, Idaho Regional Hand & Upper Extremity Center. Following her injury, Coray's physician recommended back surgery. However, after an independent medical examination (IME) requested by her employer and its surety, they denied liability for the surgery and ongoing benefits, arguing that Coray had recovered from the workplace injury and that the surgery was necessitated by preexisting conditions. After undergoing surgery outside of the workers' compensation system, her employer requested a second IME by a different physician. Coray refused and sought a declaratory ruling from the Idaho Industrial Commission on whether the employer must use the same physician for multiple examinations of a single injury.The Idaho Industrial Commission ruled that the employer or surety is not required to use the same physician for multiple examinations of a single injury under Idaho Code section 72-433. However, it also held that each request for an IME is subject to a reasonableness standard, and the burden of proof for establishing reasonableness falls on the employer. Coray appealed this interpretation, while the employer cross-appealed the Commission's conclusion that it bears the burden of proving the reasonableness of a second IME.The Supreme Court of the State of Idaho affirmed the Idaho Industrial Commission's decision. It held that the plain language of Idaho Code section 72-433 does not prohibit an employer or surety from using different physicians to perform multiple examinations of a single injury. The court also affirmed the Commission's ruling that the employer bears the burden of establishing the reasonableness of its requested IME, including its choice of physician, if raised by the employee. View "Coray v. Idaho Regional Hand & Upper Extremity Center" on Justia Law

The case involves a dispute between Blaine Simmons, a landowner, and Tom Loertscher and Josh Williams, cattle owners. Simmons owns land in Bonneville County, Idaho, which is part of a herd district established in 1919. The herd district prohibits livestock from running at large within its boundaries. Loertscher owns Hi Willow Ranch Corporation, which has a permit to graze cattle on a portion of the Bureau of Land Management (BLM) land adjacent to Simmons' property. The BLM land is designated as open range, where livestock may graze and roam freely. Over time, cattle allegedly owned by Williams, grazing on the Loertscher Allotment, have strayed onto Simmons' property. Simmons repeatedly complained to Loertscher and Williams about this and set conditions for them to retrieve their cattle from his land.Simmons filed a small claims action against Loertscher and Williams alleging herd district violations and nuisance. The magistrate judge ruled in favor of Loertscher and Williams, stating that herd district laws do not apply to the Loertscher Allotment, which is on BLM land and designated as open range. The judge also stated that Loertscher and Williams have a common law right to enter Simmons’s Parcel at reasonable times and in a reasonable manner to retrieve their cattle. Simmons appealed this decision to the district court, which affirmed the magistrate court's decision.The Supreme Court of the State of Idaho affirmed the district court's decision. The court concluded that the district court's interpretation of Idaho Code section 25-2402, which excludes open range from any herd district and reinstates Idaho’s “fence-out” rule with respect to cattle straying from open range, was consistent with the history of herd district law and the effect of the 1963 amendment. The court also affirmed the district court's decision regarding the conditions governing the retrieval of cattle from Simmons’s Parcel. The court found that Simmons did not preserve this issue for appeal before the district court, and the issue was waived before this Court. View "Simmons v. Loertscher" on Justia Law

Dale Carter Shackelford was found guilty on six counts, including two counts of first-degree murder, and was sentenced to death for the murder counts and to various terms for the other counts, all to be served concurrently. However, the death sentences were vacated due to a Supreme Court decision, and the case was remanded for resentencing. At the resentencing hearing, Shackelford was given fixed life sentences for the murder counts to be served consecutively, but the court did not address the other counts. The written judgment stated that the murder sentences were to run consecutively with each other and with the sentences for the other counts.Shackelford, representing himself, filed a motion to correct a clerical error in the judgment, arguing that it did not accurately reflect the court's oral pronouncement of sentence because the court did not mention the other counts at the resentencing hearing. He contended that the judgment should be corrected to order that the consecutive sentences for the murder counts run concurrently with the sentences for the other counts. The district court denied Shackelford’s motion, ruling that the written judgment accurately reflected the oral pronouncement of sentence.On appeal, the Supreme Court of the State of Idaho reversed the district court's decision. The Supreme Court held that when there is a difference between the oral pronouncement of sentence and the written judgment, the oral pronouncement controls. The court found that the district court's oral pronouncement at Shackelford’s resentencing was unambiguous as far as the murder counts were concerned, but did not mention the other counts. Therefore, while the murder sentences run consecutively to each other, because the district court did not state that the other counts were to run consecutively to the murder counts, they will run concurrently with the murder counts. The case was remanded to the district court to correct the judgment to conform to the oral pronouncement of sentence. View "State v. Shackelford" on Justia Law

The case involves Jameel Fakhri Al Muthafar, who was convicted for aggravated assault and attempted strangulation. Al Muthafar argued that the district court erred by denying his motion to dismiss the information after the magistrate allowed hearsay statements at the preliminary hearing over his objection. The statements were made by a nurse during a dual medical and forensic examination. Al Muthafar contended that without these inadmissible statements, there was insufficient probable cause to bind the case over to the district court. He also argued that the district court abused its discretion in sentencing him to a unified sentence of fifteen years, with five years fixed.The district court denied Al Muthafar's motion to dismiss the commitment and information, arguing that the statements fell under the Rule 803(4) hearsay exception because the State failed to establish that the victim's statements were made for the purpose of medical treatment. The case proceeded to a jury trial where both the nurse and the victim testified. At the conclusion of the trial, the jury found Al Muthafar guilty of both aggravated assault and attempted strangulation. The district court subsequently sentenced Al Muthafar to fifteen years with the first five years fixed.The Supreme Court of the State of Idaho affirmed the district court's decision. The court held that while the magistrate court erred in admitting the nurse's testimony at the preliminary hearing, Al Muthafar's judgment of conviction should nevertheless be affirmed because he received a fair trial. The court also held that the district court did not abuse its discretion by imposing a unified term of fifteen years with five years fixed. View "State v. Al Muthafar" on Justia Law

The case involves an individual, referred to as "John Doe," who repeatedly applied for admission to the Idaho State Bar. Doe's applications were denied due to concerns about his character and fitness, including his honesty, judgment, and respect for the rights of others. Doe challenged these denials, arguing that his federal lawsuits against the Idaho State Bar were a necessary defense of his rights and that his conduct was protected by the First Amendment.The Idaho State Bar filed a petition with the Idaho Supreme Court, seeking permission to reject Doe's third application and to prohibit him from filing future applications for a specified period. Doe cross-petitioned, seeking immediate admission to the Idaho State Bar.The Idaho Supreme Court denied Doe's cross-petition, finding that he had not demonstrated that he met the essential eligibility requirements to practice law. The court granted the Idaho State Bar's petition in part, allowing it to reject Doe's third application and prohibiting Doe from filing a new application for two years. The court found that Doe had not shown a significant change in his circumstances that would render him eligible to practice law. The court also ordered the Idaho State Bar to refund Doe's application fee. View "ISB v. John Doe" on Justia Law

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