Justia Idaho Supreme Court Opinion Summaries

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

This appeal stems from an arbitration decision regarding Peggy Cedillo's underinsured motorist insurance policy with Farmers Insurance Company of Idaho, and damages for injuries she suffered in a motorcycle accident. After the arbitrator issued his final award, Farmers provided the arbitrator evidence that Farmers had already paid Cedillo the total amount of remaining damages. The arbitrator adjusted the award by subtracting Farmers' payment from the prejudgment interest Farmers owed Cedillo. The district court confirmed the arbitrator's amended award and awarded Cedillo attorney fees. On appeal, Farmers argued the district court should have modified the award because the arbitrator miscalculated prejudgment interest by applying Farmers' payment to the interest award. Farmers also argued numerous grounds that Cedillo was not entitled to attorney fees. Finding no reversible error, the Supreme Court affirmed. View "Cedillo v. Farmers Insurance Co of Idaho" on Justia Law

A jury found Azad Haji Abdullah guilty of first-degree murder, first-degree arson, three counts of attempted first-degree murder, and felony injury to a child. The case proceeded to sentencing and the jury found two aggravating circumstances. The jury also found that all the mitigating circumstances when weighed against each aggravating circumstance individually were not sufficiently compelling to make the death penalty unjust. The district court subsequently entered judgments of conviction and sentenced Abdullah to death for first-degree murder and to a total of eighty years imprisonment for the remaining five convictions. Abdullah sought post-conviction relief. After an evidentiary hearing, the district court dismissed Abdullah’s petition for post-conviction relief in its entirety. Abdullah appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed the convictions, the sentences, and the order denying post-conviction relief. View "Georgia v. Abdullah" on Justia Law

The issue this case presented for the Supreme Court's review stemmed from attempts by the Water Users’ Association of the Broadford Slough and Rockwell Bypass Lateral Ditches, Inc. (Association) to collect assessments from Big Wood Ranch, LLC (BWR) for maintenance performed by the Association on the Broadford Slough (Slough) and Rockwell Bypass (Bypass), which were conduits for the delivery of surface water to property owned by BWR and some of its neighbors. The Association claimed it has a statutory right to collect assessments for its maintenance of this water delivery system. BWR disputed that claim. On summary judgment, the district court determined that the Association was validly formed pursuant to Idaho Code section 42-1301, and, after a bench trial, found BWR owed payment for these outstanding assessments. BWR appealed, challenging the validity of the Association’s formation under the statute, as well as the court’s alternative contract and equity-based theories for granting judgment in favor of the Association. Upon review, the Supreme Court found: (1) the Association was not qualified to operate pursuant to Idaho Code section 42-1301; (2)the district court erred by alternatively granting judgment to the Association on unpled contract and equity-based theories; and (3) BWR was entitled to attorney fees and costs on appeal. View "Big Wood Ranch v. Water Users' Assn. of the Broadford Slough & Rockwell Bypass Lateral Ditches, Inc." on Justia Law

In 2011, Corey Thiel was charged with felony domestic battery. Pursuant to a plea agreement, Thiel pled guilty to an amended charge of misdemeanor domestic battery and was placed on supervised probation. Approximately one week after entry of this guilty plea, Thiel was charged with a misdemeanor violation of a no-contact order for an incident that occurred while the battery charge was pending. Thiel pled guilty to violating the no-contact order, and the magistrate court imposed suspended jail time and two years of unsupervised probation, while crediting time served. Under the terms of his probation, Thiel was required to comply with the terms of supervised probation established in the underlying battery case. Less than two months thereafter, on May 2, 2012, the State moved for the court to issue a bench warrant for Thiel’s arrest based on probation violations. At a hearing on the State’s motion, Thiel admitted the violations. The court reinstated Thiel on probation. Approximately four months thereafter, the State moved for a second set of probation violations, alleging that Thiel failed to maintain contact with his assigned probation officer and also failed to provide documentation that he had completed the required domestic violence treatment. At a hearing on the State’s motion, Thiel admitted the violations. The court revoked Thiel’s probation and imposed his original sentence of 356 days, with a credit of 67 days. Fifty-five days before his sentence was to end, the Ada County Sheriff’s Office submitted a letter to the magistrate court recommending that Thiel be granted early release. The magistrate court denied the Sheriff’s request. The issue this case presented for the Supreme Court's review was one of statutory interpretation: Idaho Code section 20-621 authorizes commutation of county jail sentences for good behavior, making county inmates with good records while incarcerated eligible for five (5) days off for each and every month of their sentence. A prisoner’s eligibility, however, was conditioned upon receiving a recommendation from the supervising county sheriff. The primary issue presented here was whether the statute vested the magistrate court with the discretion to reject a recommendation from a sheriff. The Supreme Court affirmed the district court's conclusion that the statute vested no discretion with the magistrate judge. View "Idaho v. Thiel" on Justia Law

LuAnn Shubert fell and injured her lower back while working at a Macy’s store. She appealed the Idaho Industrial Commission’s order holding that she was: (1) medically stable on November 21, 2007; (2) not entitled to medical benefits beyond that date; (3) not entitled to temporary disability benefits; (4) entitled to a permanent partial impairment rating of 5% of the whole person; and (5) entitled to a 10% permanent partial disability rating. Shubert argued that she was entitled to ongoing medical care, temporary disability benefits, and total permanent disability benefits over 10%. Macy’s West (Macy’s) and Liberty Insurance Corporation argued that Shubert was rearguing the facts. Finding no reversible error in the Commission's decision, the Idaho Supreme Court affirmed. View "Shubert v. Macy's West, Inc." on Justia Law

The City of Hayden provided sewer service to the residents living in the City and to some persons living outside the City. To do so, the City entered into a joint powers agreement with the Hayden Area Regional Sewer Board, which operated a regional wastewater treatment plant serving the City and two other local entities. The City charged each customer it serves a bi-monthly fee, which covered a proportionate share of the operation and maintenance of the City's sewer collection system and of the operation and maintenance costs associated with the regional wastewater treatment facility. In addition to the bi-monthly fee, the City charged a one-time "sewer capitalization fee" for each new structure, whether residential or commercial, and for any addition to an existing commercial structure that would result in an increase in the volume of sewage generated. The capitalization fee was charged when a building permit is issued. In March 2006, the City contracted with an engineering company to update the City's sewer master plan. The engineering company submitted a capital improvement plan in which it recommended forty projects that would cost about $20 million in order to replace existing infrastructure and to construct new infrastructure so that the sewer system would reach the entire area of city impact and accommodate anticipated future population growth. In order to finance the project, the engineering company recommended that the part of the capitalization fee retained by the City be increased from $735 for one equivalent residence ("ER") to $2,280 for one ER. In 2010, the North Idaho Building Contractors Association filed suit to have the fee declared unlawful because it was an impermissible tax rather than a fee for services. The district court held that it was lawful and entered a judgment dismissing the complaint. The City requested an award of attorney fees, which the court denied. The Contractors Association appealed the dismissal of its complaint, and the City cross-appealed the denial of an award of attorney fees. Because there was nothing in the record showing that as of June 7, 2007, the sum of $2,280 was the actual cost of providing sewer service to a customer connecting to the City sewer system and there was no showing that the amount of the fee was based upon any such calculation, the fee was not authorized by Idaho Code section 63-1311(1). The Supreme Court concluded the district court erred in holding that it was. View "No. Idaho Bldg Contractors Assoc. v. City of Hayden" on Justia Law