Justia Idaho Supreme Court Opinion Summaries

Cable One, Inc., is a Delaware corporation headquartered in Phoenix, Arizona. In 2005, Cable One received business income from four types of activities in Idaho: cable television services, internet access services, advertising services, and cable modem leasing. In its Idaho income tax return for that year, it included revenues earned from all of those activities except revenues from providing internet access services to Idaho customers. It excluded those revenues on the ground that providing such services to customers in Idaho constituted Arizona sales, although it also excluded such revenues from its 2005 Arizona income tax return on the ground that they came from Idaho sales. In 2008, the Idaho Tax Commission issued a notice of deficiency determination asserting a tax and interest deficiency on Cable One for the 2005 tax year. Cable One petitioned for redetermination, which the Tax Commission denied. Cable One then filed a complaint in the district court, which tried the matter de novo, and ruled in favor of the Tax Commission. Cable One then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Cable One, Inc. v. Idaho State Tax Commission" on Justia Law

April Fano and Right Way Publishing, LLC, appealed a district court's judgment following a bench trial in which found Fano liable for breaching a Release Agreement. Judgment was entered in favor of respondent Vianna Stibal for damages, punitive damages and attorney fees and costs. While Fano and Stibal were involved in prior litigation, they reached a settlement through mediation and signed a Release Agreement, which mutually released Stibal and Fano from liability to each other for their acts prior to the agreement. The Release Agreement prohibited the parties from making any future negative or disparaging comments about the other. Prior to executing the Release Agreement, Fano had provided negative information about Stibal to a book author. Fano also formed a limited liability company and paid to print 500 books about Stibal. The books were printed before the Release Agreement was executed. Stibal subsequently brought the present action, alleging that Fano had breached the Release Agreement. The district court ruled that Fano was responsible for the comments and documents contained in the book, "Shady Healing," which it determined were obtained from the previous litigation. The district court also found: (1) Fano was substantially involved in bringing "Shady Healing" to market, including providing the book's author with information Fano obtained from the previous litigation with Stibal; (2) paying to print 500 copies of the book; and (3) being a manager of Right Way Publishing, LLC. The district court ruled that "Shady Healing" would not have been published but for Fano's involvement, and that this action coupled with Fano's failure to disclose the existence of the book constituted a breach of the Release Agreement. Fano argued on appeal that the district court erred when it ruled that she breached the Release Agreement because all of the activity complained of occurred before the Release Agreement was executed. Upon review, the Supreme Court concluded Fano was correct: the uncontroverted evidence was that Fano did not sell, promote or distribute the book. Without evidence of a breach, the district court's finding of a breach of the Release Agreement was clearly erroneous. It followed that Fano was not liable to Stibal for any damages, and accordingly, the Court did not address the other issues raised on appeal with respect to damages. The judgment entered by the district court against Fano was reversed. View "Stibal v. Fano" on Justia Law

Spirit Ridge Mineral Springs, LLC appealed a judgment entered in favor of Franklin County dismissing Spirit Ridge's complaint which had requested abatement of a private nuisance and for an injunction against a gun range operated by Franklin County adjacent to its property. In a bench trial, the district court ruled that Spirit Ridge had failed to demonstrate that there was an ongoing and continuing nuisance at the time of the trial. Spirit Ridge appealed. The Supreme Court affirmed: the district court record reflected a lack evidence to show that a nuisance existed after 2008. View "Spirit Ridge Mineral Springs v. Franklin County" on Justia Law

Gary Schall was arrested for driving under the influence of alcohol. He had two prior convictions for driving under the influence within the previous ten years, one of which stemmed from a 2004 arrest in Wyoming. As a result of his prior convictions, the State enhanced his DUI charge to a felony. At the preliminary hearing, the magistrate found that there was probable cause to bind the case over to district court. Schall filed a motion to dismiss in the district court, arguing that the State had the burden at the preliminary hearing to provide probable cause to believe his Wyoming DUI conviction was for a "substantially conforming foreign criminal violation," that the State failed to meet that burden, and that the Wyoming conviction was not in fact a substantially conforming violation. The district court denied Schall's motion, finding that the State met its burden at the preliminary hearing and that the Wyoming statute substantially conformed to Idaho's DUI statute. Schall appealed and the Court of Appeals reversed. The State appealed, and now the Supreme Court reversed, concluding the district court correctly denied Schall's motion to dismiss. View "Idaho v. Schall" on Justia Law

Jonathan Ellington was convicted of second-degree murder and two counts of aggravated battery. He moved for a new trial, arguing that he discovered new material evidence that could not have been produced at trial through reasonable diligence. The evidence consisted of statements in a textbook authored by the State's accident reconstruction expert that, according to Ellington, directly conflicted with the expert's trial testimony. The district court denied Ellington's motion. Upon review of Ellington's arguments on appeal, the Idaho Supreme Court concluded the district court did not abuse its discretion in denying Ellington's motion for a new trial. View "Idaho v. Ellington" on Justia Law

The State appealed a district court's grant of Micah Wulff's motion to suppress evidence obtained in a warrantless blood draw. The draw took place after Wulff was in custody for driving under the influence. The district court held that the United States Supreme Court's holding in "Missouri v. McNeely," suggested that warrantless blood draws are not always permitted under Idaho's implied consent statute. The State argued that McNeely was limited to the exigent circumstances exception to the warrant requirement and Idaho's implied consent statute is a valid exception to the warrant requirement. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Wulff" on Justia Law

This appeal stemmed from the sale of dairy cattle that were subject to Appellant Farmers National Bank’s (FNB) perfected security interest and Respondent J&M Cattle Company’s (J&M) agister’s lien. The net sale proceeds received from the sale of the dairy cattle were insufficient to satisfy both FNB’s perfected security interest and J&M’s agister’s lien. J&M filed an action for declaratory relief to resolve FNB’s and J&M’s competing interests. Although FNB’s perfected security interest had a priority date that predates J&M’s lien, the district court determined that J&M’s lien had priority over FNB’s perfected security interest. The district court entered a final judgment in favor of J&M, and FNB appealed. Finding no reversible error, the Supreme Court affirmed the district court's decision. View "J&M Cattle Co v. Farmers National Bank" on Justia Law

John Doe was the biological father of T.C. Doe was a juvenile when T.C. was born. Doe paid Mother a total of $52.00 in child support, despite a court order requiring him to pay Mother child support of $253.00 per month. Doe owed approximately eight thousand dollars in unpaid child support. Doe never provided T.C. or Mother with any alternate form of support such as clothing, diapers, or food. During T.C.’s life, Doe was regularly incarcerated and had no contact with T.C. for months at a time; including a substantial period of time that the child protection proceedings were ongoing. Doe has been unable to maintain employment or a home and typically resides in the homes of various girlfriends. Doe was addicted to methamphetamine and, when not in custody, he used methamphetamine. Doe had an extensive criminal record and has been a defendant in more than forty criminal matters. A petition was filed under the Child Protective Act (CPA) asking a magistrate court to place T.C under the supervision of the Department. The same day, the magistrate court ordered the removal of T.C. on the basis that continuation in the home would be contrary to T.C.’s welfare. The magistrate court placed T.C. in the care of the Department of Child Services. Doe learned of the Department’s petition when his aunt informed him of the proceedings. His parental rights to T.C. were ultimately terminated on grounds that the trial court found Doe neglected T.C., and that it was in the child's best interests to have Doe's parental rights terminated. Doe appealed, but finding no reversible error, the Supreme Court affirmed the trial court's order. View "Health & Welfare v. John Doe (13-29)" on Justia Law

Claimant-appellant Francisco Serrano worked as a framer for Four Seasons Framing from 2001 to 2008. He was injured in two work-related accidents. He appealed an Industrial Commission finding that he failed to prove that the condition for which he was claiming benefits was caused by the two accidents in 2004 and 2008. Finding no reversible error in the Industrial Commission's order, the Supreme Court affirmed. View "Serrano v. Four Seasons Framing" on Justia Law

At the center of this appeal was ABC Agra, LLC's action seeking a declaratory judgment against Critical Access Group, Inc. ("CAG") regarding the enforceability of a real property use restriction. Because there were no existing or proposed uses that implicated the restriction, the district court determined that the claim was not ripe and granted CAG's 12(b)(6) motion to dismiss. Finding no reversible error, the Supreme Court affirmed this dismissal. View "ABC Agra v. Critical Access Group" on Justia Law