Justia Idaho Supreme Court Opinion Summaries

This appeal stemmed from a 1983 Ground Lease of property in Pocatello which Quail Ridge Medical Investors, LLC (Quail Ridge) leased from Pocatello Hospital, LLC d/b/a Portneuf Medical Centers, LLC (PMC). Previously, Quail Ridge appealed a declaratory judgment entered by the district court which found PMC was entitled to an adjustment in the annual rent owed by Quail Ridge from $9,562.50 annually to $148,500 annually, and that Quail Ridge was obligated to pay PMC $416,812.50 in rent for the period at issue. The Supreme Court affirmed the court’s declaratory judgment. While the first appeal was pending, PMC filed a new action seeking payment of the adjusted rents. In the second action, the district court found on summary judgment that Quail Ridge breached the Ground Lease by failing to pay the adjusted rents. Quail Ridge appealed, arguing the breach of contract and breach of guarantee claims are barred under res judicata. Finding no reversible error, the Supreme Court affirmed. View "Pocatello Hospital v. Quail Ridge Medical Investor" on Justia Law

This case arose out of a professional negligence claim relating to a life insurance policy. Bill Gailey purchased the life insurance policy from Kim Whiting in 2010. In August 2011, Gailey cashed in the life insurance policy after receiving advice from Whiting to that end. Gailey suffered negative tax consequences from cashing in the policy and subsequently filed a complaint against Whiting alleging Whiting was negligent when he advised Gailey to cash in his policy without warning him of the potential tax consequences. Whiting subsequently moved the court to dismiss the action for lack of personal jurisdiction because Whiting no longer lived in Idaho, Gailey was a resident of Oregon, and the alleged tort did not occur in Idaho. The district court granted Whiting’s motion and Gailey appealed to this Court. Finding no reversible error, the Supreme Court affirmed. View "Gailey v. Whiting" on Justia Law

In 2012, Idaho State Police stopped defendant-respondent Derek Arrotta for a traffic violation. At the end of the stop, defendant was issued a citation for misdemeanor driving while under the influence of alcohol. Defendant filed a motion to suppress “based on violations of the defendant’s right to be free from unreasonable search and seizure, right to remain silent, right to counsel, and related constitutional protections under the State of Idaho Constitution and the United States Constitution,” but the motion did not identify what evidence he wanted to suppress or how his rights were allegedly violated. The parties agreed to postpone the matter until the United States Supreme Court decided "Missouri v. McNeely." After the Supreme Court issued its opinion in McNeely, the magistrate court held an evidentiary hearing on the motion to suppress. The trooper testified to the events and stated that he did not recall telling Defendant that he did not have a right to refuse the blood test. However, he also testified that he told Defendant that if he refused the breath test, the trooper would get a blood draw. Defendant testified that he refused the breath test, but not the blood test. He testified that at the hospital he asked if he could refuse the blood test, “but they pretty much said no.” When asked if the trooper told Defendant he could not refuse the blood draw, Defendant answered, “Yeah, something to that extent.” The magistrate court did not resolve the factual dispute regarding whether Defendant was told that he could not refuse the blood draw. Rather, it held that statutory implied consent was insufficient by itself to constitute consent to a search in the form of a blood draw; that express consent was required. Based upon that holding, the court granted Defendant’s motion and issued an order suppressing the blood test results. The State appealed to the district court. The district court affirmed the suppression order, holding that statutory implied consent to a blood draw is revocable. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Arrotta" on Justia Law

"Mother" Jane Doe appealed a magistrate court’s judgment that terminated her parental rights to three of her children. The magistrate court concluded that the Idaho Department of Health and Welfare (“IDHW”) proved by clear and convincing evidence that Mother and father John Doe neglected their children and that terminating parental rights was in the children’s best interests. Mother argued on appeal that IDHW did not show clear and convincing evidence, the court failed to properly consider her disability, and IDHW did not make reasonable efforts to help her comply with her case plan. Finding no reversible error, the Supreme Court affirmed the magistrate court’s judgment terminating Mother’s parental rights. View "Idaho Dept. of Health & Welfare v. Jane Doe (2014-17)" on Justia Law

This case centered on a proposed easement over a rough, relatively unimproved, single-vehicle dirt road that travels over property the City of Twin Falls owned in the Snake River Canyon, south of the Snake River. H.F.L.P., LLC owned three parcels in the Snake River Canyon, west of Rock Creek. At trial, H.F.L.P. claimed it had a prescriptive easement and an easement by necessity over the property, but the district court ultimately entered judgment in favor of the City. H.F.L.P. argued on appeal that the district court: (1) did not have subject matter jurisdiction over the case; (2) erred when it held that H.F.L.P. failed to prove a prescriptive easement and an easement by necessity; and (3) erred when it admitted photographic overlays over H.F.L.P.’s objections at trial. Finding no reversible error, the Supreme Court affirmed. View "H.F.L.P. v. City of Twin Falls" on Justia Law

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