Justia Idaho Supreme Court Opinion Summaries

Todd Hamilton died in an automobile accident while employed by Alpha Services, LLC. The Idaho Industrial Commission found that the accident arose out of and in the course of Hamilton’s employment and determined that Hamilton’s widow and two children were entitled to statutory death benefits under Idaho’s worker’s compensation laws. Alpha and its surety, Dallas National Insurance Company, argued on appeal to the Supreme Court that the Commission’s decision was not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Hamilton v. Alpha Services, LLC" on Justia Law

In October 2012, an Ada County Sheriff’s officer stopped a vehicle for failing to maintain its lane. The officer identified the driver as defendant Alesha Green, and it was subsequently discovered that Green was driving with an invalid driver’s license, which Green admitted to knowing. The officer testified at Green’s preliminary hearing that he had no reason to believe Green was someone other than who she identified herself to be, nor did the officer have reason to believe Green would not appear for court. Although driving without a valid license in violation of Idaho Code section 49-301 was a misdemeanor offense, it was not an arrestable offense unless certain conditions are met. Those conditions were not met here. Nonetheless, the officer arrested Green. The resulting search of Green’s person produced alleged drugs and drug paraphernalia. Additionally, a large amount of cash was discovered during the search of Green’s vehicle. Once transported to the Ada County Jail, Green made incriminating statements and gave consent to search her hotel room, where police found a digital scale and small plastic bags. Green was charged with a number of drug-related offenses under two different case numbers. The State appealed the district court’s order granting a motion to suppress evidence. The Supreme Court reversed: "[a]s stated at the outset, we recently reiterated that in order for the Idaho Constitution’s interpretation to deviate from the interpretation of the U.S. Constitution, there must be clear precedent to that effect or circumstances unique to the state of Idaho or its Constitution that would compel such a result. [. . .] Although Green cites several Idaho cases, arguing that long-standing Idaho jurisprudence establishes that suppression is appropriate where there has been a statutory violation that impacts one’s constitutional rights, an examination of those cases reveals that Green’s position is without merit. Whether or not discussed by the Court in its respective decisions, each statute directly at issue in 'Rauch,' 'Mathews,' and 'Card' has a historical, pre-constitution source of the currently codified principles. Therefore, suppression in each of those cases was justified by a direct violation of principles inherent in the Idaho Constitution. There is no historical counterpart to Idaho Code section 49-1407 that was present at the time the Idaho Constitution was adopted. Therefore, it cannot be said that the principles in that section limiting certain warrantless misdemeanor arrests to specific circumstances are constitutional in nature. Likewise, a violation of that statute is not a constitutional violation. Because there was no pre-constitution counterpart to Section 49-1407, a violation of this section is merely statutory in nature. And, because there was no constitutional violation in this case, suppression was inappropriate." View "Idaho v. Green" on Justia Law

Doe and C.C.’s mother (Mother) are the biological parents of C.C., who was born in 2008. Doe, Mother, and C.C. are all members of the Shoshone-Bannock Tribes of the Fort Hall Reservation (Tribes). Doe and Mother were never married, but lived together sporadically during the initial portion of C.C.’s life until Mother ended the relationship in 2010. In July of 2010, Doe shot Mother in front of C.C. Doe pleaded guilty to Attempted First Degree Murder and was sentenced to serve fifteen years, with nine years fixed. He was not eligible for parole until July of 2019. Mother married C.C.’s stepfather on October 15, 2010. Stepfather was also a member of the Tribes. The issue in this case presented for the Supreme Court's review centered on a magistrate court’s judgment terminating John Doe’s parental rights and allowing C.C. to be adopted. Doe argued that the magistrate court did not have jurisdiction to hear the case. Finding no reversible error, the Supreme Court affirmed. View "Termination of Parental Rights of John Doe (2014-25)" on Justia Law

Appellant Saint Alphonsus Regional Medical Center submitted third party medical indigency applications on behalf of two patients. Respondent Elmore County and the Board of Elmore County Commissioners denied the applications because the Board determined that the applications were incomplete. Saint Alphonsus filed petitions for judicial review. The district court consolidated the cases and affirmed the Board’s decision. The issue presented for the Supreme Court's review centered on the statutory interpretation of the Medical Indigency Act. Specifically, the issue reduced to whether a third party’s application for financial assistance (Saint Alphonsus) was a “completed application” with signatures from only the third party applicant and not the patient. The two relevant provisions for this issue were Idaho Code sections 31-3502(7) and 31-3504(1). Based on its interpretation of these statutes, the Supreme Court held that a third party’s application was a “completed application” with signatures from only the third party applicant, therefore the application did not require the signature of the patient to be “completed” under the Act. The Court vacated the district court's judgment and remanded the case for further proceedings. View "St. Al's RMC v. Elmore County" on Justia Law

James and Barbara Hilliard (Vendors) owned a farm in Owyhee County with approximately 3,000 acres of farmable land. They executed written leases of the best farm ground to various farmers who grew row crops. They orally leased to John Clark other portions of the farm, on which he raised hay and grain crops. In 2009 and 2010, Vendors leased the row crop portion of the farm to Lance Funk Farms, LLC. Because of his health, on John Clark became unable to continue farming, and Vendors orally leased to his son Jay P. Clark, Vendors’ attorney, those parts of the farm not leased for growing row crops. According to Vendors, in January 2010 Jay Clark fraudulently obtained a written document purporting to give him a one-year lease of the entire farm with an option to extend the lease for a period of ten years. He then recorded the document in the records of the county recorder, and in June 2010 his father recorded a document claiming to have a 10% interest in the farm. These recordings created clouds on the Vendors’ title to the farm. In November 2010, Vendors contracted to sell their farm to Murphy Land Company, LLC (Purchaser). Jay Clark told Purchaser that he would only vacate the farm upon payment to him of $2,000,000 and payment to his father of $950,000. Because of the two clouds on the title and the refusal of Jay Clark to vacate the property, the parties entered into an amendment to their contract which stated, among other things, that $3,000,000 of the sale price would be held in trust to “be available to the extent determined by a court of competent jurisdiction of the purchaser’s damage, if any, for loss or delay of possession of real estate purchased herein.” The sale closed on December 30, 2010. In early 2011, Vendors sued Jay and John Clark, and obtained a judgment declaring Jay Clark’s purported lease null and void and ordering that John Clark’s recorded claim to ownership of a 10% interest in the farm be expunged from the county records. Then Purchaser filed a lawsuit to have Jay Clark removed from the farm. Clark fought that lawsuit, including filing for bankruptcy protection after Purchaser was granted summary judgment in its action to remove him from the farm. As a result, Purchaser did not obtain possession of the farm until May 2012. In 2013, Vendors filed this action for a declaratory judgment that they were entitled to a $3,000,000 being held in trust. Purchaser filed a counterclaim seeking that sum for the damages it incurred due to the delay in being able to obtain possession of the farm. The district court granted summary judgment to the purchaser after holding that the material portions of the affidavits filed by the vendors in opposition to summary judgment were inadmissible. Finding no error with that judgment, the Supreme Court affirmed the district court and awarded attorney fees on appeal. View "Hilliard v. Murphy Land Co." on Justia Law

This is an appeal from a judgment dismissing the plaintiff’s claims seeking to recover damages resulting from being bitten by a police dog when she was mistaken for a burglar. On appeal, Plaintiff argued that “[t]he district court was critical of [the Plaintiff] for failing to articulate a narrowly and clearly defined constitutional right of which objectively reasonable police officers would be aware.” According to the Plaintiff, “That, of course, is a self-defeating proposition for any litigant, plaintiff or defendant, because it forces the litigant to guess what the court deems specifically narrow enough to fit whatever undefined parameter it will ultimately use.” Thus, she asserted that the clearly established right at issue should be that she “had the basic and fundamental right not to be attacked by a police dog simply because she was mistaken for a burglar by overzealous police officers.” The Supreme Court found plaintiff's formulation of the issue as "clearly wrong;" "[i]t assumes that the Police knew that the Plaintiff was 'mistaken for a burglar.' [. . .] There is no constitutional right not to be mistaken for a criminal." Finding no reason to disturb the district court's judgment, the Supreme Court affirmed. View "James v. City of Boise" on Justia Law

Plaintiff-appellant Gary Holdaway filed suit against Broulim’s Supermarket, alleging that a titanium screw implanted in his leg was fractured when an automatic door at Broulim’s malfunctioned and closed on the leg. Broulim’s filed a motion for summary judgment arguing that Holdaway failed to provide admissible evidence that the malfunctioning door fractured the screw and caused the resulting medical complications. The district court agreed, granted the motion, and Holdaway appealed. Finding no reversible error, the Supreme Court affirmed. View "Holdaway v. Broulim's Supermarket" on Justia Law

At the heart of this appeal was a judgment resolving a dispute between two neighbors. In 1994, defendants Eric and Rosalynn Wurmlinger built their home in the Park Wood Place subdivision in Post Falls, on a lot next to the home of Judy Richardson. The Defendants operated a bed and breakfast from their home, and they planted a row of arborvitaes near the property line between their lot and the lot owned by Richardson. In 2005, plaintiff Christina Greenfield purchased the Richardson property. The following year, Plaintiff had an attorney write to the Defendants, stating that the operation of their bed and breakfast violated the subdivision’s protective covenants, conditions, and restrictions (CC&R’s) and that the height of the arborvitaes violated the height restriction on fences contained in the CC&R’s and the height restriction on hedges contained in a city ordinance. Thereafter, the dispute between Plaintiff and Defendants centered on the operation of Defendants’ bed and breakfast in their home and the height of their arborvitaes near the boundary between the two properties. By 2010, the arborvitaes had grown to a height of ten to twelve feet. In April, Defendants returned from a vacation and discovered that about four to six feet had been cut from ten of their arborvitaes; Plaintiff had her agent cut the trees. Plaintiff was charged criminally, but the charges were later dismissed. Over a period of about eighteen months, there were fourteen incidents of paint being splashed or poured on improvements to their property, with the last incident occurring about four months before the jury trial in this case. In September 2010, Plaintiff filed this action alleging four claims against Defendants: (1) a declaratory judgment that Defendants were violating the CC&R’s by operating the bed and breakfast and allowing their arborvitaes to grow higher than five feet (obstructing a pedestrian easement across their property); (2) the plants and trees on Defendants’ property that blocked her view of the Spokane River constituted a nuisance; (3) Defendants had agreed to maintain their foliage along the common boundary line at a height of six feet and Plaintiff had the foliage trimmed to the agreed height when they grew taller; and (4) Defendants breached their agreement with her and made false and defamatory statements about her to law enforcement, which negligently caused her emotional distress. The trial court found that Defendants did not violate the subdivision CC&R’s by operating a bed and breakfast from their home or by having arborvitaes higher than six feet, and awarded them a judgment totaling $168,755.37 against the plaintiff for her conduct that caused them emotional distress. Plaintiff appealed, but finding no error in the trial court's judgment, the Supreme Court affirmed the district court and award attorney fees on appeal. View "Greenfield v. Wurmlinger" on Justia Law

Defendant-appellant Kristi Hurles pled guilty to grand theft for embezzling from her employer, was sentenced to fourteen years with two years fixed, and was ordered to pay $204,174.61 in restitution. Hurles worked at a restaurant, primarily responsible for maintaining the books, but from time to time, Hurles waited tables and tended the bar. One of her duties as bartender was to sell and pay out on Idaho State Lottery pull-tabs. When the restaurant's owners noticed they were losing money on the lottery pull-tabs, they investigated and learned that Hurles’ payouts on the game were over 12% higher than the maximum possible payout for the game. A lottery investigator concluded that Hurles had inflated the amount of the payouts by approximately $10,000 over the course of a year and pocketed that amount. Hurles appealed her conviction, challenging the restitution order. The Court of Appeals reversed the restitution order in part, affirmed in part, and remanded the case to the district court. The State sought review, which the Supreme Court granted. After review, the Supreme Court affirmed the district court's order requiring restitution in the amount of $10,000 for Hurles’ theft of lottery pull-tab monies. The Court reversed restitution ordered for attorney fees in the amount of $33,857.88 for the third-party lawsuits and a bankruptcy adversary proceeding, and the Court vacated the restitution order for ATM thefts in the amount of $145,440 and the remaining amount of attorney fees incurred by the owners. The case was remanded to the district court for determination of restitution relating to the ATM thefts and the owners’ fees incurred in determining and presenting their embezzlement losses. View "Idaho v. Hurles" on Justia Law

Defendant-respondent Moses Olivas, Jr. was convicted of failing to register as a sex offender. Pursuant to Idaho Code section 18-8311(1), the district court sentenced Olivas to a term of imprisonment of five years. The district court also revoked Olivas's probation on a prior conviction, executed the underlying sentence from that conviction, and retained jurisdiction. The district court ordered the underlying sentence and the five-year sentence for failing to register as a sex offender to run consecutively. Following the period of retained jurisdiction on the prior conviction, the district court suspended Olivas's underlying sentence and reinstated probation. The State appealed the district court's order suspending Olivas's sentence on the prior conviction. The Court of Appeals affirmed the district court's decision. The State petitioned the Supreme Court for review. But finding no reversible error, the Supreme Court affirmed. View "Idaho v. Olivas" on Justia Law