Justia Idaho Supreme Court Opinion Summaries

In 2012, a Post Falls police officer was searching for a gray truck with stolen Washington license plates. He located and began to follow the truck, and he confirmed that the license plate on it was stolen. The truck stopped in a parking lot in Post Falls, and the officer told the driver, later identified as defendant Dennis Halseth, to stay in the vehicle. Defendant drove away, with the officer in pursuit. Defendant was later stopped and arrested in Washington by a Washington state trooper. The trooper asked Defendant to complete voluntary field sobriety tests, and Defendant refused. The trooper then transported Defendant to a hospital in Spokane, Washington, to have his blood drawn for evidentiary testing. Despite defendant's protests, the hospital technician drew blood samples from each of defendant’s arms. No search warrant was obtained prior to the blood draws. The State of Idaho charged defendant with several crimes including driving while under the influence of alcohol, which would be a felony because of his prior convictions. Defendant moved to suppress the evidence on the ground that he did not consent to the warrantless search. He did not contend that the trooper lacked probable cause to believe that he had been driving under the influence of alcohol. In light of the decision of the United States Supreme Court in "McNeely," the State did not argue that the natural dissipation of alcohol in the bloodstream was an exigent circumstance justifying a warrantless search, nor did it argue that there were any other exigent circumstances justifying the search. The State argued that both Washington and Idaho had statutes providing that persons who drove on public roads impliedly consented to a test for alcohol concentration in their blood; and that Idaho case law held that there was no legal right to withdraw that implied consent; and that the implied consent included a blood draw. The district court granted the motion to suppress, and the State appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Halseth" on Justia Law

Defendant Juan Luis Sanchez-Castro was indicted, tried, and convicted of one count of conspiracy to traffic in 400 grams or more of methamphetamine and one count of trafficking in 400 grams or more of methamphetamine. For each crime, he was sentenced to fifteen years in the custody of the Idaho Board of Correction, with the first ten years fixed and the remaining five years indeterminate, and a fine of $25,000. The district court ordered that the prison sentence on the second charge run concurrently with the prison sentence on the first charge. Defendant appealed, arguing that the conspiracy charge and the trafficking charge were, under Idaho law, the same charge. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Sanchez-Castro" on Justia Law

In 2010, plaintiffs Terri Boyd-Davis and Brian Davis filed suit to determine the boundary line between their property and their neighbors, defendants Timothy and Carol Baker. The district court entered a partial judgment quieting title in the disputed property. The Bakers appealed, and Boyd-Davis cross appealed. The district court’s construction of the deeds changed all of the calls in both deeds. The Supreme Court concluded that was not a reasonable construction of the deeds. "It does not matter whether the Clarks intended to give Jean Coleman more land than was reasonably contained within the legal descriptions of her deeds. Changing the calls, particularly the call of the southern boundary of the 1970 deed, takes land that under our recording statutes was deeded to the Bakers. We therefore reverse the partial judgment of the district court." Because the Court reversed the partial judgment, it did not consider the other issue raised by the Bakers on appeal. View "Boyd-Davis v. Baker" on Justia Law

Scott Avery Reed (Father) and Stephanie M. Reed (Mother) were married in 1993, and during their marriage they had three children. On December 22, 2009, Mother filed for divorce. They agreed that there were irreconcilable differences between them that justified terminating their marriage. The remaining issues were tried in the magistrate court on January 13 and 14, 2011. On appeal, Father raised multiple alleged errors. The Supreme Court vacated four parts of the decision pertaining to the division of property, and remanded the case for further proceedings. View "Reed v. Reed" on Justia Law

Claimant Newman K. ("Kal") Giles was involved in a one-vehicle accident during the course of his employment. The evidence was undisputed that Kal was driving at approximately 123 mph in a 50 mph zone at the time of the accident, that he was legally intoxicated with a blood alcohol concentration (BAC) of .11%, that he was very familiar with the road and the particular curve where the accident happened, and that he was not wearing a seatbelt. Kal also claimed to have been texting in the time leading up to the accident, though evidence of the alleged texting was not raised until opening argument at the evidentiary hearing nearly four years after the accident. The Idaho Industrial Commission conducted the hearing on the sole issue of whether Kal was barred from receiving income benefits by Idaho Code section 72-208. The referee found intoxication was a reasonable and substantial cause of the accident and injuries and concluded that Kal was barred from receiving income benefits under Idaho Code section 72-208. The Commission adopted the referee’s findings as its own. Kal appealed and finding no reversible error, the Supreme Court affirmed. View "Giles v. Eagle Farms, Inc." on Justia Law

Franklin Building Supply Co., Inc. (“FBS”) filed suit against Aaron Michael Hymas to recover money owed on an open account for construction supplies, equipment, and labor supplied to Crestwood Construction, Inc. FBS claims that Hymas guarantied any unpaid balance on Crestwood’s account. The district court granted FBS’s motion for summary judgment. Shortly thereafter, the district court permitted FBS to correct an error in an affidavit submitted in support of summary judgment regarding the amount of interest owed on the outstanding balance. Hymas twice moved the court to reconsider its order granting summary judgment and the district court denied both motions. He timely appealed. Finding no reversible error, however, the Supreme Court affirmed. View "Franklin Building Supply Co. v. Hymas" on Justia Law

Mercedes Turner filed suit against her former employer, the City of Lapwai, claiming that she was owed unpaid compensation and reimbursement for certain expenses incurred during her employment. The City moved for summary judgment, arguing that Turner’s claim for unpaid compensation was barred by the applicable statute of limitations and that both claims were barred because Turner failed to provide adequate notice of her claims as required by Idaho Code section 50-219. The district court granted summary judgment in favor of the City, holding that Turner failed to provide adequate notice of her claims. Turner appealed. Upon review, the Supreme Court affirmed because Turner failed to file her claim with the city clerk as required by Idaho Code sections 50-219 and 6-906. Consequently, the other issues raised on appeal by Turner and the City were not addressed. View "Turner v. City of Lapwai" on Justia Law

Claimant-appellant Trudy Deon brought worker compensation claims against her employer, H&J, Inc., and its surety, Liberty Northwest, (Employer/Surety) and the Idaho Special Indemnity Fund (ISIF). Deon eventually settled with ISIF but the claim against Employer/Surety went to a hearing that resulted in the Idaho Industrial Commission finding Employer/Surety 100% liable for her total and permanent disability (TPD). The Commission decided sua sponte to reconsider its decision and invited the parties to brief the issue of whether Deon was estopped from arguing Employer/Surety was 100% liable, given her settlement with ISIF. In an order on reconsideration, the Commission held that Deon was so estopped and apportioned 23.92% of her TPD to Employer/Surety. Deon appealed. Upon review, the Supreme Court determined the Commission erred by sua sponte raising the issue of collateral estoppel. The Commission and Employer/Surety knew about the ISIF settlement agreement for months before a decision was rendered and never raised the estoppel issue. Deon filed complaints against both her Employer/Surety and the ISIF. As a result of mediation, she reached a tentative settlement agreement with ISIF on October 5, 2012. The agreement was reduced to writing, signed by the parties on October 19, 2012, and approved by the Commission on November 8, 2012. When the Commission issued its Decision, it determined that Deon was totally and permanently disabled and that Employer/Surety was 100% liable under the odd-lot doctrine as Deon had argued. After considering all the hearing evidence and the parties’ briefing, the Commission found apportionment between the ISIF and Employer/Surety “is not appropriate” because “[t]he record does not establish that Claimant’s pre-existing leg condition combined with her 2008 industrial accident to render her totally and permanently disabled. However, on the same day the Commission issued its Decision, it also issued a notice of reconsideration pursuant to Idaho Code section 72-718, which raised for the first time the collateral estoppel. Specifically, the Commission wanted to know whether Deon’s stipulation to ISIF’s partial liability for her TPD estopped her from then arguing that Employer/Surety was 100% liable. After the parties briefed the issue, the Commission issued a new order holding that Deon was estopped from asserting a position inconsistent with her stipulation that ISIF was partially liable for her TPD. It then apportioned TPD liability according to the "Carey" formula, changing Employer/Surety’s liability from 100% to 23.92%. The Supreme Court concluded the revised findings were hinged solely on the Commission’s erroneous view of the law, and were without any support in the hearing record. Therefore, the Court reversed the Order on Reconsideration. Because the Commission did, in fact, hear Deon’s claim against Employer/Surety on the merits and determined Employer/Surety was 100% liable, Deon was entitled to 100% of her benefits from Employer/Surety. View "Deon v. H &J, Inc." on Justia Law

Christian Westby, James Westby, and Kristina Westby appealed the district court’s denial of their motion to reconsider the court’s protective order granted to Mercy Medical Center and Dr. Gregory Schaefer. This case arose from the Westbys’ claim that Dr. Schaefer’s and Mercy Medical’s negligence resulted in lifelong brain damage to Christian Westby. Near the end of discovery, the district court granted Mercy Medical and Dr. Schaefer’s protective order motion to prohibit the Westbys from deposing Mercy Medical and Dr. Schaefer’s expert witnesses. The district court later denied the Westbys’ motion to reconsider that protective order. The Westbys argued on appeal to the Supreme Court that the district court abused its discretion by not requiring any showing of good cause or unreasonable delay and basing its decision on a mistaken belief that the Westbys were dilatory. The Supreme Court agreed that the trial court erred, vacated the order and remanded the case for further proceedings. View "Westby, et al v. Schaefer, M.D." on Justia Law

This case consolidated several individual cases dealing with claims for nonpayment against the developer of the Summer Wind at Orchard Hills residential and golf course development in Canyon County. Stanley Consulting, Inc. appealed the district court’s decision as to the priority date for Stanley’s engineer’s lien. Integrated Financial Associates, Inc. (“IFA”) cross-appealed the district court’s decision granting Knife River’s summary judgment motion based on the court’s decision that Knife River had a valid priority lien for paving work it did on roadways and golf cart paths without having to designate the lien between the two projects. After its review of the claims, the Supreme Court concluded the district court erred when it determined an engineer’s priority under Idaho Code section 45-506 for rendering professional services dates back to when the first on-site professional services were rendered. Furthermore, the Court held the district court erred when it granted summary judgment in favor of Knife River on its lien claim priority. Accordingly, the district court’s judgments were vacated and the case is remanded for further proceedings. View "Stanley Consultants v. Integrated Financial Associates" on Justia Law