Justia Idaho Supreme Court Opinion Summaries

Daniel Ehrlick appealed his conviction for the first-degree murder of a child and the failure to report the death to law enforcement. In the summer of 2009, the Ada County Sheriff's dispatch received an emergency call from Ehrlick reporting that R.M., the eight-year-old son of his live-in girlfriend, Melissa Jenkins, was missing. Ehrlick told dispatchers that R.M. was last seen at 7:00 p.m. on July 24, he had been searching for R.M. for several hours, and everyone was telling him that R.M. was at a birthday party. In the ensuing days, an extensive search was launched to find R.M. The searchers included members of several law enforcement agencies and dozens of citizen volunteers. R.M.'s body was found on August 3, 2009, floating face down in a canal. A large rock was stuffed into a closed cargo pocket of his pants. No evidence was offered as to how, or precisely when, R.M.'s body was placed in the canal. R.M.'s corpse exhibited extensive injuries, including multiple compression injuries to the abdomen and a blow to the head. Both the compression injuries and the head injury were potentially fatal wounds on their own, but would not have resulted in instantaneous death. The State's forensic pathologist testified that R.M.'s death was caused by blunt force trauma to the head and torso due to an assault. Investigators began to suspect Ehrlick and Jenkins were involved in R.M.'s disappearance. Investigators searched the couple's apartment and found a piece of paper taped to a wall which concealed a hole in the drywall. Investigators eventually had the section of drywall scanned in order to create a three dimensional plastic model that was introduced at trial. Investigators suspected that the hole was created when Ehrlick slammed R.M.'s head into the wall. A grand jury returned an indictment charging Ehrlick with first-degree murder and failure to report a death to law enforcement. After trial, a jury unanimously found Ehrlick guilty of both charges. The district court sentenced Ehrlick to two fixed consecutive life sentences. On appeal, Ehrlick argued that the trial court committed multiple errors in the admission of evidence and that the prosecution violated his Fourteenth Amendment right to a fair trial by committing multiple acts of prosecutorial misconduct. Finding no error, the Supreme Court affirmed. View "Idaho v. Ehrlick" on Justia Law

Claimant Gina Poledna was employed by Thorne Research, Inc. (Employer). Her work required repetitive tasks, and over time she began experiencing pain in her wrists. She saw a physician who diagnosed her as having ganglion cysts in both wrists. Her physician stated that Claimant could return to work and recommended that she wear a brace. The physician saw Claimant again and noted that her pain “fairly well quieted down” and that she has “slight discomfort with excessive twisting . . . otherwise she can do what she wants.” Claimant’s wrist pain worsened, and she returned to her physician a few years later, who informed her that she had bilateral carpal tunnel syndrome and that her work caused the pain to get worse. After receiving that diagnosis, Claimant met with Employer and requested other work duties that did not require the repetitive motion of her current job. Employer told her that no other type of work was available. Claimant decided that she would quit her employment. She went on vacation on Thursday, December 19, 2013, and on December 30, 2013, she gave Employer a clinic note from her physician. Employer told Claimant that there were no light duty positions available. Claimant decided not to return to work with Employer, so her last day of employment was December 18, 2013. Claimant filed a claim for unemployment benefits, which was denied. She appealed to an appeals examiner. In a report prepared by Claimant's physician, the physician stated that he did not advise Claimant to “[t]ake time off from work,” to “[c]hange occupations,” to “[m]ove to another area,” or to “[d]iscontinue working.” He further stated that the only limitation of which he advised her regarding the kind, amount, conditions, or place of her work was that she was to wear a brace at work. Finally, he stated that Claimant could work full time. During the hearing, Claimant admitted that her physician never told her that she needed to quit her job. The appeals examiner issued a decision denying Claimant unemployment benefits because “there is no evidence in the record to suggest her medical condition made work impossible,” which Claimant was required to prove in order to establish that she quit work with good cause connected to her employment. Claimant the appealed to the Industrial Commission, which later upheld the appeals examiner’s decision not to reopen the hearing, and it concluded that Claimant voluntarily quit her job without good cause because she failed to prove that her job was unsuitable due to her medical condition. The Commission found that the medical records from Claimant’s treating physician were more credible than Claimant’s assertions. Claimant then appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed the Commission. View "Poledna v. Dept of Labor" on Justia Law

John Doe and his wife had two children born during their marriage. They later divorced, and the children’s mother died from strangulation in 2011. Doe was arrested and charged with murder in connection with her death. He had been held in custody since his arrest. A jury found John Doe guilty of murder in the first degree, for which he was sentenced to life in prison without eligibility for parole during the first twenty-five years. He appealed his conviction. The children’s maternal grandparents were appointed their temporary guardians, and filed this action to terminate John Doe’s parental rights. While Doe was still appealing his sentence for murder, the guardians filed an amended petition adding a claim to adopt the children. The magistrate court tried the claim to terminate John Doe’s parental rights. The court issued its findings of fact, conclusions of law, and order finding that termination of John Doe’s parental rights was in the best interests of the children and that three statutory conditions existed justifying the termination. Doe then timely appealed. In 2015, the Supreme Court entered a decision vacating the jury verdict finding John Doe guilty of murder and his judgment of conviction because the district judge wrongly excluded evidence that the jury could have found corroborated his testimony that he did not kill the children’s mother. Because the judgment was based solely upon the jury verdict finding John Doe guilty of murdering the children’s mother and his judgment of conviction, both of which were vacated on his appeal in the criminal case, the Supreme Court vacated the judgment terminating his parental rights and remanded this case for further proceedings. View "Dept. of Health & Welfare v. John Doe (2014-26)" on Justia Law

Appellant Matthew Lamont and Respondent Krissy Lamont were married and have two minor children. After the divorce, Krissy was granted primary physical custody of the children, and until recently Krissy and Matthew resided in Salmon, Idaho. In June of 2014, however, Matthew learned that Krissy planned to relocate with the children to Meridian, Idaho. He filed a petition in magistrate court to modify the divorce decree to obtain primary physical custody of the children. Krissy filed a cross-petition to relocate the children to Meridian. After a hearing, the magistrate court denied Matthew’s motion and granted Krissy’s motion. Matthew appealed, but finding no abuse of discretion, the Supreme Court affirmed. View "Lamont v. Lamont" on Justia Law

The appeal in this case arose after a jury found Desiree Eliasen guilty of misdemeanor stalking. Following the jury’s verdict, Eliasen moved the magistrate court for a judgment of acquittal, which the magistrate court denied. Eliasen subsequently appealed to district court, arguing the State failed to prove she engaged in "repeated acts" constituting a "course of conduct" under the statute. The district court upheld the jury’s verdict and Eliasen appealed. The Idaho Court of Appeals affirmed, and Eliasen then petitioned the Supreme Court for review. On review, Eliasen argued that there was insufficient evidence to show that she was guilty of misdemeanor stalking because she did not engage in separate instances of stalking. Instead, Eliasen claimed her conduct was one continuous act and therefore insufficient to satisfy the "course of conduct" element under the misdemeanor stalking statute. Finding no reversible error, the Supreme Court affirmed the district court’s decision upholding the jury’s verdict. View "Idaho v. Eliasen" on Justia Law

Elmore County’s decided to terminate employee, plaintiff-appellant Cherri Nix, without providing her a pre-termination hearing pursuant to the Elmore County Personnel Policy (ECPP). Nix filed suit alleging, among other claims, that Elmore County violated the ECPP and breached the covenant of good faith and fair dealing when it terminated her employment without giving her a pre-termination hearing. The district court granted Elmore County’s summary judgment motion on the basis that Nix was an at-will employee subject to termination at any time and for any reason, and that Nix failed to show a contractual relationship with Elmore County that would entitle her to a pre-termination hearing. Nix appealed, but finding no reversible error, the Supreme Court affirmed. View "Nix v. Elmore County" on Justia Law

Defendant-appellant Kenny Struhs pled guilty to vehicular manslaughter, was sentenced to a unified term of fifteen years in prison with ten years fixed, and was ordered to pay restitution to the victim's widow, including an amount compensating her for health insurance premiums she paid for coverage between the time of the accident and the time of Struhs' sentencing. On appeal, Struhs challenged the sentence as excessively harsh and the award of restitution for insurance premiums as unauthorized under Idaho Code section 19-5304. Finding no cause to disturb the trial court's judgment, the Supreme Court affirmed. View "Idaho v. Struhs" on Justia Law

Defendant-appellant Katherine Stanfield was convicted by jury for first degree murder of two year-old W.F. by aggravated battery of a child under twelve years. Defendant raised two issues on appeal: (1) the district court erred in admitting certain expert testimony, claiming that the testimony's admission violated her Sixth Amendment right to confrontation and that the evidence was inadmissible hearsay; and (2) the district court deprived her of her Fourteenth Amendment right to due process and right to a jury trial by failing to properly instruct the jury. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Stanfield" on Justia Law

The issue this case presented for the Supreme Court's review centered on respondents Daryl and Linda Mullinix's right to use appellant Killgore's Salmon River Fruit Co.'s pipeline to convey water from Joe Creek. Both parties had water rights pursuant to partial decrees from the Snake River Basin Adjudication (SRBA) to obtain water from Joe Creek. The parties also entered into a private Settlement Agreement, which required that Mullinix's point of diversion was below Killgore's point of diversion on Joe Creek. After the parties entered into this Agreement, Mullinix filed a complaint against Killgore seeking to use Killgore's pipeline to convey water. Killgore counterclaimed. After a bench trial, the district court ordered that Mullinix could use Killgore's pipeline, but Mullinix had to install a weir below Killgore's weir to satisfy the point of diversion clause in the Agreement. The water from Mullinix's weir would then join Killgore's pipeline to reach Mullinix's property. After the district court issued its order, Killgore prevented Mullinix from obtaining an easement on the property of a nonparty to install the weir. As a result, the district court ordered that Mullinix could forgo the separate point of diversion and instead install a tap on Killgore's pipeline as it crossed Mullinix's property. Killgore appealed, and the Supreme Court affirmed in part, vacated in part, and remanded. The Court vacated the district court's order that Mullinix pay an annual water delivery fee to Killgore. In all other respects, the district court's second amended final judgment was affirmed. View "Mullinix v. Killgore's Salmon River Fruit Co." on Justia Law

The Idaho Supreme Court granted a petition for review of a Court of Appeals decision in this case. Irwin Adams appealed a district court’s decision summarily dismissing his post-conviction relief petition, which the Idaho Court of Appeals affirmed. Adams argued on appeal that the district court erroneously: (1) weighed the State’s accident reconstruction expert’s trial testimony against Adams’s accident reconstruction expert’s affidavits; (2) reached its own conclusions as to purported flaws in Adams’s accident reconstruction expert’s conclusions; and (3) wrongfully determined that even if Adams’s accident reconstruction expert’s testimony would have been presented at trial, it would not have changed the outcome of the case. Adams also argued that the district court erred when it dismissed the claim that trial counsel was ineffective for failing to investigate and present evidence that Adams’s vehicle was incapable of going the speeds the State alleged during trial. Finding no reversible error, the Supreme Court affirmed the district court’s decision. View "Adams v. Idaho" on Justia Law