Justia Idaho Supreme Court Opinion Summaries

The issue before the Supreme Court in this case concerned the district court’s holding that Ashton Urban Renewal Agency (AURA) had standing to challenge a property tax exemption granted to Ashton Memorial, Inc., a corporation with real and personal property located within AURA’s revenue allocation area. Specifically, the issue was whether AURA was a “person aggrieved” under I.C. 63-511, and therefore, could appeal the grant of the exemption to the Idaho Board of Tax Appeals (BTA). The Supreme Concluded that AURA was an "person aggrieved" under the statute, therefore it affirmed the district court's decision. View "Ashton Urban Renewal v. Ashton Memorial" on Justia Law

Defendant-Appellant Joseph Clinton was indicted for felony lewd conduct with a minor under sixteen. Initially he was found incompetent to stand trial, but after reassessment, he was deemed competent. Thereafter he pled guilty, and underwent further assessment prior to receiving sentence. The sentencing court ultimately sentenced defendant to twenty years' incarceration, three years fixed and the remainder indeterminate. Defendant moved for reduction of the sentence, which was denied. The Court of Appeals affirmed defendant's sentence. The issues on appeal to the Supreme Court were: (1) whether the trial court erred in failing to order a mental evaluation sua sponte; and (2) whether the sentencing court abused its discretion in imposing defendant's ultimate sentence. Finding no errors, the Supreme Court affirmed. View "Idaho v. Clinton" on Justia Law

Defendant-Respondent-Appellant Stephen Adams appealed a district court judgment that upheld a magistrate judge's order that dismissed his motions to modify child custody and child support. Defendant's had been held in contempt for failing to make one child support payment. He was unable to purge the contempt by paying all delinquent child support payments for reasons he said were beyond his control. A court can impose a criminal contempt sanction in nonsummary contempt proceedings only if the contemnor has been afforded the federal constitutional rights applicable to criminal contempt proceedings. The magistrate held that it could refuse to hear the Father's motions because he was unable to purge the contempt and could not prove that his inability was due to circumstances beyond his control. The district court held that refusal to hear the Father's motions was a permissible criminal contempt sanction. Idaho Code section 7-610 does not authorize denial of access to the courts as a criminal contempt sanction. Therefore, the district court erred in affirming the magistrate's order on the ground that it was a permissible criminal contempt sanction. The Supreme Court held that the district court erred in affirming the magistrate court's order. In addition, the Supreme Court held that refusal to hear a motion and dismissal of a motion that the contemnor did not purge the contempt violates Article I, Section 18 of the state constitution. The district court was reversed and the case remanded. View "Slane v. Adams" on Justia Law

In 1997, Plaintiff-Respondent Donald Steuerer needed money and asked his across-the-street neighbor N.E.M. Richards to loan him some. Richards agreed to loan Steuerer $5,000. Steuerer executed and recorded a warranty deed conveying a half interest in his property. Richards paid additional funds Steuerer's benefit, and Steuerer contemporaneously executed a quitclaim deed to the property in favor of Richards. The parties later disputed: (1) how much Richards had paid to or for the benefit of Steuerer and (2) whether the deeds were intended as absolute conveyances or mortgages to secure repayment of the loans. Steuerer filed suit against Richards seeking to quiet title to the property. The district court found: (1) the deeds executed by Steuerer to the Property were intended by the parties to be mortgages to secure loans made by Richards to Steuerer; (2) Steuerer owed Richards $9,285.11 plus prejudgment interest; and (3) upon payment of the monetary award, Richards had to re-convey the property to Steuerer. Richards appealed to the Supreme Court, arguing the district court's judgment was not "sustained by the facts found." Finding no error in the district court's judgment, the Supreme Court affirmed. View "Steuerer v. Richards" on Justia Law

Judgment creditor PAL I, LLC levied and executed upon collateral in which KeyBank had a perfected security interest. PAL argued that because KeyBank did not file a third-party claim to the collateral in accordance with I.C. 11-203, it waived its interest in the collateral. The district court held that a perfected security interest survives a creditor's failure to comply with the statute, that KeyBank's security interest extended to the proceeds PAL realized from the sheriff's sale of the collateral, and that KeyBank was entitled to judgment against PAL in that amount. PAL appealed to the Supreme Court. Finding no error, the Supreme Court affirmed. View "Keybank Nat'l Assoc v. Pal I, LLC" on Justia Law

Appellant Lillian Hatheway appealed a district court's grant of summary judgment in favor of the Board of Regents of the University of Idaho and the University of Idaho. Appellant worked for the University as an administrative assistant for nine years before she resigned. She sued for age discrimination, hostile work environment, retaliation, constructive discharge and negligent infliction of emotional distress. Upon review, the Supreme Court concluded the district court correctly dismissed all of Appellant's claims. View "Hatheway v. Bd of Regents - UI" on Justia Law

At issue in this case was a medical malpractice claim brought against a physician's assistant, two supervising physicians and Rocky Mountain Emergency Physicians, LLC. Plaintiff-Appellant Heather Hall went to the emergency room complaining of headache, blurred vision and sensitivity to light. The assistant examined her, and in the process, plaintiff alleged the assistant touched her inappropriately while trying to listen to plaintiff's heartbeat through a stethoscope. Plaintiff's medical expert opined that this conduct fell below the standard of care for a physician's assistant working in an emergency room in Pocatello. Rocky Mountain moved for summary judgment, arguing that the expert lacked proper foundation. The district court granted Rocky Mountain's motion and dismissed the suit. Finding no error in the district court judgment, the Supreme Court affirmed. View "Hall v. Rocky Mtn Emergency Physicians" on Justia Law

Claimant Rubio Izaguirre settled with a third-party tortfeasor following a work-related automobile accident. His employer and surety asserted a right of subrogation against the entirety of that settlement. On appeal, claimant argued that subrogation rights should have extended only to damages that workers’ compensation typically insures and not to pain and suffering. The Commission found in favor of the employer and surety, holding that all of the settlement proceeds were subject to subrogation. Finding no error, the Supreme Court affirmed. View "Izaguirre v. R&L Carriers" on Justia Law

In this case, Thomas and Mary Ulrich sought to quiet title to an easement over the "Peacock Parcel," which is adjacent to land that they own. The Peacock Parcel is owned by four parties. The Ulrichs brought suit against “all parties claiming to hold title” to the Peacock Parcel, but served only one of the owners, John Bach. The district court quieted title to the easement in the Ulrichs, declared the Ulrichs’ easement to be superior to any right claimed by Bach, and enjoined Bach from interfering with their use of the easement. Bach appealed that decision to the Supreme Court. Upon review, the Court affirmed that portion of the district court’s judgment granting an injunction against Bach, but vacated the portion of the judgment quieting title to the property. View "Ulrich v. Bach" on Justia Law

Defendant-Appellant Timothy Dunlap received the death penalty following his guilty plea to first-degree murder. He appealed the sentence, alleging multiple errors during trial, and that he received ineffective assistance of counsel. Although the Supreme Court found found error in the direct appeal from the sentencing proceedings, it held those errors, individually and cumulatively, were harmless. As to the appeal of the order summarily dismissing defendant's petition for post-conviction relief, the Court held that the district court erred in summarily dismissing defendant's claim of ineffective assistance of counsel regarding the investigation and presentation of mitigating evidence and the rebuttal of the State’s evidence in aggravation and defendant's "Brady/Napue" claim. Therefore, the Court vacated the district court’s judgment granting summary dismissal of defendant's petition for post-conviction relief and remanded the case for further proceedings. View "Idaho v. Dunlap" on Justia Law