Justia Idaho Supreme Court Opinion Summaries

Richard Pines, D.O. appealed the district court’s decision on a disciplinary order of the Idaho Board of Medicine. The Board brought disciplinary proceedings against Pines following reports that he had induced young men into sexual contact by saying he was required to give full-body massages to naked practice patients in order to be relicensed as a doctor of osteopathy. Following a hearing, the Board found Pines committed four counts of professional misconduct. It revoked Pines’ license and ordered that he pay costs and attorney fees. The district court affirmed the four counts of misconduct but vacated the award of costs and attorney fees. Pines appealed and the Board cross-appealed. Before the Supreme Court, Pines argued: (1) that he was disciplined for uncharged conduct, resulting in a violation of his due process rights; (2) that evidence in the record was insufficient to support certain alleged violations made against him; (3) that as applied, his due process rights were violated by the Board's conclusion that four individuals were Pines' patients. The Board argued that the district court erred in vacating the Board's order on attorney fees and costs. Upon review of the record, the Supreme Court found that two of the "patients" were not, indeed, Pines' patients, and that Pines' due process rights were not violated. The Court affirmed the Board's decision on Counts I and II, but vacated the district court's decision on Counts III and V (which pertained to the two "patients"). The case was remanded for further proceedings, including additional consideration of the issue of costs and fees. View "Pines v. Idaho Board of Medicine" on Justia Law

The Federal National Mortgage Association (“FNMA”) purchased Russell Hafer’s home at a non-judicial foreclosure sale. FNMA filed an eviction suit when Russell and his wife, Sandra, refused to vacate. The Hafers claimed that the foreclosure sale was invalid because their loan servicer, American Home Mortgage Services, Inc.(now known as Homeward Residential, Inc.), agreed to modify the terms of Russell’s loan just prior to instituting foreclosure proceedings. They claimed that Russell was therefore not in default at the time of the sale. The Hafers filed a third-party complaint against Homeward, stating eleven causes of action and asking the district court to quiet title in Russell. FNMA and Homeward filed a joint motion for summary judgment, arguing that there was no agreement to modify the loan terms because Russell did not sign and return a permanent loan modification agreement to Homeward by the specified deadline. The district court granted the motion in favor of FNMA and partially granted the motion in favor of Homeward, holding that there was no agreement between Homeward and Russell modifying Russell’s loan because no Homeward representative signed an agreement. The Hafers appealed, arguing: (1) the district court erred in considering the question whether an agreement had to be signed by a Homeward representative when that issue was not raised in the joint motion for summary judgment; and (2) that the district court erred substantively in concluding that there was no agreement to modify Russell’s loan absent a signature from a Homeward representative. Upon review, the Supreme Court concluded that the district court erred in dismissing the Hafers' first, third, and fourth causes of action against Homeward, as well as granting FNMA's claim for possession. The case was remanded for further proceedings. View "Federal National Mortgage Association v. Hafer" on Justia Law

Virgil Adams appealed a district court’s order granting summary judgment in favor of Kimberley One Townhouse Owner’s Association, Inc. Adams purchased a townhouse, subject to a declaration of covenants, conditions, and restrictions (1980 Declaration) that did not specifically restrict an owner’s ability to lease his or her unit. Subsequently, the Association amended the 1980 Declaration to provide that an owner could not rent a unit for a period of less than six months. Adams argued the amendment constituted an invalid restraint on the free use of his land and that he did not have notice of the possibility of such a restriction under the general provision allowing “amendment” in the 1980 Declaration. Finding no reversible error in the district court's decision, the Supreme Court affirmed. View "Adams v. Kimberley One Townhouse Owner's Association, Inc." on Justia Law

The State of Idaho appealed a district court judgment denying its motion to vacate portions of a Stipulated Partial Settlement and Award entered by an arbitration panel. This case stemmed from the 1998 Tobacco Master Settlement Agreement, wherein certain cigarette manufacturers entered into an agreement with the State to pay damages for the cost of treating smoking-related illnesses. A dispute arose between the parties as to the amount owed in 2003 and the district court entered an order compelling arbitration. The arbitration panel entered a Stipulated Partial Settlement and Award in March of 2013. In June of 2013, the State moved the district court to vacate, modify, or correct the award. The district court concluded the State did not have standing to move to vacate or modify the award. The State appealed. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Philip Morris, Inc." on Justia Law

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