Justia Idaho Supreme Court Opinion Summaries

A woman sleeping in the bedroom of her apartment in Nampa, Canyon County, Idaho, awakened to see an unknown male standing over her with a knife in his hand. He was wearing a mask that covered his face and exposed his eyes. He put a hand over her mouth and held a knife against her throat, and stated that she was going to cooperate. He initially attempted several sexual acts, but was unable to obtain an erection. He then had her lie on her back at the bottom of the bed, where he raped her. He wore a condom and used his cell phone to take photos of her during the rape. Before leaving, he took her sheets and a pillow case. He also had her remove the battery from her cell phone, and he placed it under clothing in her panty drawer. She ran to a neighbor’s house, where she called 911. Defendant was immediately the focus of law enforcement - Nampa police had been investigating him for an assault and battery in Nampa that took place a year earlier. Defendant was ultimately convicted for rape, first degree kidnapping, and burglary. Defendant challenged the admission of evidence first discovered in the warrantless search of his cell phone and of evidence regarding his rape fantasies and his possession of pornography depicting rape. Upon review of this matter, the Supreme Court held that the information obtained during the warrantless search of defendant's cell phone was admissible under the independent source doctrine and that the district court did not abuse its discretion in admitting evidence regarding the Defendant’s rape fantasies and his pornography depicting rape. View "Idaho v. Russo" on Justia Law

A grand jury indicted Michael Koch on four counts of lewd conduct with a minor under sixteen with “C.C.” named as the complaining witness in all counts. Count I alleged the crime was committed “by manual to genital and/or oral to genital contact” between January and May 2011. Counts II, III, and IV all alleged genital to genital contact in April 2011. On appeal, Koch argued the district court made multiple errors in the admission of evidence that warrant reversal of his judgment of conviction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Koch" on Justia Law

These are two cases out of Bannock County that were consolidated on appeal. In the first case, defendant was convicted of attempting to elude a peace officer, a felony, and of malicious injury to property and assault, both misdemeanors. In the second case, defendant was convicted of grand theft, a felony. For each felony, he was sentenced to eighteen years in prison, with eight years fixed and ten years indeterminate, and the sentences were ordered to be served consecutively. On appeal of both cases, defendant challenged the evidence presented against him, and alleged procedural errors by the trial courts to reverse the sentences he received. Upon review, the Supreme Court found no reversible errors, and affirmed defendant's convictions and sentences. View "Idaho v. Skunkcap" on Justia Law

What began as a disagreement between neighbors, ended with defendant-appellant Nathan Herren being charged with misdemeanor malicious injury to property - a charge to which he pled guilty. The magistrate court entered a withheld judgment and a no contact order in July 2008, which stated "[i]t is hereby ordered that [Herren] shall not contact (including: in person or through another person, or in writing or e-mail, or by telephone, pager, or facsimile) or attempt to contact, harass, follow, communicate with, or knowingly remain within 100 feet of: Kip McDermott.” In January 2009, despite knowing that McDermott would likely be present, Herren attended a homeowner’s association meeting at a local elementary school. Herren arrived prior to McDermott and sat in the middle of the room. Once McDermott arrived, Herren moved from his seat in the middle of the room to the back of the room, but did not leave the meeting. McDermott contacted law enforcement because of Herren’s continued presence at the meeting. Herren was arrested and charged with the crime of violation of a no contact order. The arresting officer testified that the room was seventy-five feet long. Herren testified that he decided to stay at the meeting because he believed the room was more than 100 feet long. However, Herren admitted that he returned to the library at a later date, measured the room, and found the room was eighty-one feet long on the diagonal. The magistrate court found Herren guilty of violating the no contact order because he knowingly remained within 100 feet of McDermott. The State filed a motion alleging that Herren had violated the terms of probation in the malicious injury to property case. Herren admitted to violating his probation. As a consequence, the magistrate court revoked Herren’s withheld judgment and entered a judgment of conviction for misdemeanor malicious injury to property. Herren appealed both his judgment of conviction for violating the no contact order and the revocation of his withheld judgment for the malicious injury to property charge. The district court rejected Herren’s argument and determined that there was substantial evidence to support the magistrate court’s determination that Herren was guilty of violating the terms of the no contact order by willfully remaining within 100 feet of McDermott. The district court affirmed Herren’s judgment of conviction and the finding that he had violated the terms of his probation. Herren appealed and the Court of Appeals, in a split decision, reversed. The State appealed, and after its review, the Supreme Court affirmed in part, and reversed in part. The Supreme Court found there was not substantial and competent evidence to support a conviction under the no-contact order. However, substantial and competent evidence was in the record to support the revocation of Herren's probation. View "Idaho v. Herren" on Justia Law

Crystal Edgar and Brad Carr were the parents of D.C., born in 2003. Edgar and Carr were never married. Both Edgar and Carr have served in the Idaho National Guard since D.C.'s birth, resulting in custody disputes arising from the parties' deployments. Edgar's contempt convictions arose from Carr's allegation that Edgar committed two separate violations of the parties' Parenting Plan, which was incorporated into the magistrate court's Order for Entry of Stipulation for Decree Regarding Paternity, Child Custody and Child Support (the May 12 Order). The magistrate court heard Carr's contempt allegations, and found Edgar guilty on two counts. On Count I, the magistrate court sentenced Edgar to five days jail, suspended, a $5,000 fine, suspended, and placed her on two years unsupervised probation. On Count III, the magistrate court sentenced Edgar to three days in jail, to be served immediately. More than a month later, and after Edgar had completed serving her jail time, the magistrate court entered its Judgment of Contempt and found that Edgar "willfully violated the court order that specifically provided that decisions concerning which school [D.C.] would attend be made jointly by the parties." The magistrate court also concluded that Edgar "blatantly breached her obligation of good faith and fair dealing when she summarily denied [Carr's] last chance to see his son before being sent to a war zone where many fathers have not returned." Edgar appealed. The district court issued its Memorandum Decision and affirmed the magistrate court's decision. Upon review, the Supreme Court concluded the magistrate court erred by convicting Edgar of contempt on a basis different from that which was alleged in Carr's affidavit and the district court erred in affirming that conviction. Accordingly, the Court reversed the judgment of conviction. View "Carr v. Edgar" on Justia Law

Claimant-appellant Kevin Hope injured his right shoulder in 2003 while he was working for Empro Professional Services. He argued to the Industrial Commission that the Idaho Industrial Special Indemnity Fund (ISIF) was liable for part of his income benefits because he was totally and permanently disabled due to pre-existing back and shoulder injuries that combined with his 2003 shoulder injury. If Hope's total and permanent disability resulted from the combined effects of his 2003 shoulder injury and impairments that pre-existed that injury, then ISIF was liable for the portion of income benefits caused by the pre-existing injuries. Hope appealed the Commission's order that ISIF was not liable for any of Hope's benefits. The Commission found that Hope was totally and permanently disabled, but had failed to prove that his disability was a result of pre-existing back and shoulder impairments combined with his last shoulder injury. Hope argued that the Commission's decision was based on errors of law and fact. Finding no reversible error, the Supreme Court affirmed the Commission's order. View "Hope v. Industrial Special Indemnity Fund" on Justia Law

Dennis Sallaz and Renee Baird were married in Oregon in 1996. Baird filed for divorce in Idaho in 2004. The magistrate court entered a partial decree at the request of the parties, granting the divorce in 2005. The decree included a certificate in accordance with Idaho Rule of Civil Procedure (I.R.C.P.) 54(b) certifying the decree as a final judgment upon which execution may issue and an appeal may be taken. Neither party ever appealed from the certified judgment. The magistrate court conducted a subsequent trial regarding the division of property and debts, and issued its amended findings of fact and conclusions of law in 2007. After several post-trial motions, the magistrate court entered an amended order in 2012, settling property and debt issues. Sallaz filed a notice of appeal to the district court a few months later. Then Baird filed for Chapter 7 relief in bankruptcy. The filing of the bankruptcy petition stayed the appeal in the district court until Sallaz received permission from the bankruptcy court to pursue the appeal. Jeremy Gugino, the bankruptcy trustee, intervened in the appeal as a real party in interest. While the appeal from the magistrate's division was pending before the district court sitting in its capacity as the intermediate appellate court, Sallaz filed an independent action in Ada County asserting for the first time that the Oregon marriage was invalid. The bankruptcy trustee intervened and filed a motion to dismiss the action on the basis that it was an impermissible collateral attack on the magistrate court's property settlement order. Sallaz then requested that the district court, as the intermediate appellate court, remand the case to the magistrate division to determine the validity of the marriage. The district court held that Sallaz's challenge to the validity of the marriage was untimely, that Sallaz had impermissibly raised an issue for the first time on appeal, and that Sallaz was estopped by his inconsistent positions from challenging the parties' marriage. Sallaz requested that the Supreme Court to remand the case to the magistrate court for a determination regarding the validity of the marriage. The Supreme Court denied Sallaz's motion. Sallaz then appealed the district court's intermediate appellate decision and continued to challenge the validity of the parties' marriage in Oregon. On the intermediate appeal in the district court Sallaz asserted that the marriage was invalid because the marriage ceremony allegedly was performed by an individual who was not authorized to perform marriage ceremonies, and (for the first time), that the marriage ceremony was invalid because no Oregon marriage license could be found of record. Under either theory, Sallaz argued that invalidity of the marriage deprived the magistrate court of subject matter jurisdiction to grant a decree of divorce. Upon review, the Supreme Court affirmed the district court's determination that the magistrate court had subject matter jurisdiction to terminate the parties' marriage and divide the community property. View "Gugino v. Sallaz" on Justia Law

The issue this case presented for the Supreme Court's review centered on the reformation of a deed to real property. Appellant Augusta Greenheart challenged a district court decision that determined a warranty deed conveying a portion of land "with their appurtenances" did not transfer a water right to Greenheart as the purchaser of the property. The district court ordered the warranty deed reformed due to mutual mistake, and grounds of quasi-estoppel and waiver, and granted the sellers of the property, respondents Jay and Christine Brown, full water rights to the property. The district court entered a judgment reforming the deed accordingly and awarded attorney fees to the Browns as prevailing parties. Finding no reversible error, the Supreme Court affirmed the district court's judgment. View "Brown v. Greenheart" on Justia Law

Tracy Sales brought suit against spa owner Stacie Peabody, claiming that she contracted a toe infection as a result of a pedicure performed at the spa. The district court granted summary judgment against Sales after concluding that she had failed to present sufficient evidence of causation. The district court also denied Sales' motion for reconsideration based on the ground that she had not adequately alleged the theory of negligence she relied on in support of that motion. Sales timely appealed to the Supreme Court. And after its review, the Court concluded that the district court erred in denying Sales' motion for reconsideration. The decision was vacated and the case remanded for further proceedings. View "Sales v. Peabody" on Justia Law

In August 2006, Nagel Beverage Company approached the Youth Ranch and the Idaho Youth Ranch Foundation, Inc., about the sale of the real property. Nagel was looking to sell the property as part of a 1031 exchange and offered it to the Youth Ranch for $1,136,000 below the appraised value as a noncash donation. The Youth Ranch wanted to purchase the property and began to explore financing options with Key Bank. The Ada County Board of Equalization (the BOE) denied an application for a property tax exemption that the Youth Ranch and Idaho Youth Ranch Nagel Center, LLC asked for resulting from the donation. The Idaho Board of Tax Appeals affirmed that decision. The Youth Ranch and the LLC appealed. Ruling on the parties' cross-motions for summary judgment, the district court held that the property was not exempt from taxation. Finding no reversible error, the Supreme Court affirmed. View "Idaho Youth Ranch v. Ada County Bd of Equalization" on Justia Law