Justia Idaho Supreme Court Opinion Summaries

The State appealed a district court's judgment granting Defendant Trevor Booth's petition for post conviction relief on the grounds that Defendant received ineffective assistance of counsel. In 2005, Defendant was accused of the shooting death of Leonard Kellum. Defendant was subsequently charged for first-degree murder. The State declined to seek the death penalty in this case. Defendant's attorney prepared a memorandum outlining his understanding of the potential penalties he would face. The attorney discussed the nuances of the statutory aggravating circumstances and the risks associated with taking the case to trial. Defendant then entered into a plea agreement with the State, agreeing to plead guilty first-degree murder. After a failed appeal challenging his sentence, Defendant filed for post-conviction relief. The court concluded that Defendant's attorney erroneously advised Defendant of the consequences of his plea agreement. The Supreme Court found that the district court did not err in concluding that Defendant's attorney was deficient, and that Defendant was prejudiced as a result. The Court affirmed the district court's decision to grant Defendant post-conviction relief. View "Booth v. Idaho" on Justia Law

Plaintiffs Stephen and Marilee Bell hired contractor Defendant Perception Construction Management, Inc. (PCM) to build a log home. The parties' relationship deteriorated, and the Plaintiffs terminated the contract before construction was complete. Plaintiffs refused to pay PCM's final invoices, and PCM filed suit to enforce a lien it placed on the home for the unpaid invoices. Plaintiffs filed multiple counterclaims, including construction defect and breach of contract. PCM prevailed at trial, and the district court found PCM was entitled to damages, prejudgment interest and attorney fees. Plaintiffs appealed, contending that the district court erred by excluding certain evidence relating to their defense against the lien, and in its determination of the monies allegedly owed under the lien. The Supreme Court found that the district court impermissibly excluded Plaintiffs' evidence, and as such, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Perception Construction Management, Inc. v. Bell" on Justia Law

Jacklin Land Company (Jacklin) owned real property that it developed into a commercial industrial complex. The development was subject to multiple covenants, conditions and restrictions (CC&Rs). One of the CC&Rs was that the development was not intended for retail businesses. In April 2008, Blue Dog RV, a retailer, began negotiating with Jacklin about the purchase of land in within the complex. During the course of the negotiations, Blue Dog also discussed renting four undeveloped lots across the street, but still within the complex. KL Properties owned those four lots. Ultimately Blue Dog leased space from KL Properties. Citing the CC&Rs, Jacklin sent notice to Blue Dog to vacate the KL leased space. When further negotiations between the parties proved unfruitful, Jacklin filed suit to enjoin KL Properties and Blue Dog from using the space for RV retail. The trial court ruled in KL and Blue Dog's favor. On reconsideration, the court issued an injunction against Blue Dog for violation of the CC&Rs. Upon review, the Supreme Court found that the district court's injunction was technically flawed because it did not give "explicit notice of precisely what conduct was outlawed," and that it enjoined unknown persons who were not party to this action. The Court vacated the district court's judgment, and remanded the case for further proceedings. View "Jacklin Land Co. v. Blue Dog RV, Inc." on Justia Law

Appellant Lynnette Patterson argued that she was constructively discharged from her position with the Fraud Unit of the state Department of Health and Welfare (IDHW) due to her complaints about an intra-office romance between her supervisor and a lateral employee. IDHW had a strict policy regarding romantic relationships between supervisors and employees. Ms. Patterson made multiple complaints regarding the relationship which she alleged resulted in her first negative performance review with the IDHW, culminating in a "constructive discharge." In 2007, she filed a complaint with the Human Rights Commission (IHRC) then with the district court. The court granted summary judgment to the IDHW, finding that Ms. Patterson did not file her claim within a proscribed 180 day period following her initial complaint, and that she failed to demonstrate that her complaint was a "protected activity" in order to sustain her claim. On appeal to the Supreme Court, Ms. Patterson argued that the district court erred in its determination. Upon consideration of the trial record, the Supreme Court affirmed the district court's decision, concluding that the evidence presented at trial was sufficient to support the dismissal of Ms. Patterson's case. View "Patterson v. Dept. of Health & Welfare" on Justia Law

At issue in this case were the rights of three brothers who were residuary beneficiaries under a testamentary trust. One of the brothers leased the trust property when the trust terminated. The other two brothers sued him and the trustee to determine their respective rights. The one brother appealed the district court's judgment that found the trust was properly terminated and that he was not entitled to compensation for improvements he made to the property. Upon careful consideration of the district court record, the Supreme Court found there were genuine issues concerning reimbursement for the improvements made to the property. The Court reversed the district court on that issue, but affirmed the lower court as to all other issues. The case was remanded back to the district court for further proceedings. View "Beus v. Beus" on Justia Law

Petitioner-Appellant Stan Hawkins appealed a decision by the Bonneville County Board of Commissioners that granted his neighbors Dale and Mary Meyers variances to replace aging homes on two parcels of their land. The parcels in question were originally zoned as agriculture, and each contained homes built before the 1940s. People living on the Meyers' land regularly used a road over Mr. Hawkins' land for access. Bonneville County enacted its zoning ordinance in 1959, after the homes on the Meyers' land were built and occupied. The ordinance required dwellings to have frontage along a county-approved road. No easement was ever granted across Mr. Hawkins' land, nor was a public road officially designated to the Meyers' property. The Meyers filed for variances in 2007 believing that they needed to comply with the frontage requirement. At a hearing, the Commissioners found that the Meyers' did not need variances because their property had been "grandfathered in" so that the frontage requirement did not apply. However, the Commissioners granted the variance anyway. A trial court dismissed Mr. Hawkins' petition for review, holding that he did not have standing to file a petition for judicial review, and he did not show that the County had prejudiced any of his substantial rights. Upon review of the trial court record, the Supreme Court found that Mr. Hawkins had standing to pursue his petition for judicial review. However, the Court dismissed his petition because he did not show any prejudice to his substantial rights. Accordingly, the Court affirmed the trial court's order dismissing Mr. Hawkins' petition. View "Hawkins v. Bonneville Cty. Bd. of Commissioners " on Justia Law

Appellants David and Marsha Steed are the former employers of Claimant Marsha Fearn. Ms. Fearn resigned from her job in April 2009, and sent an email with her personal contact information to approximately 7500 of the Steeds’ sales contacts. Upon finding out about this email, the Steeds terminated Ms. Fearn's employment. A state Department of Labor (DOL) appeals examiner and the Industrial Commission (Commission) both determined that the Steeds failed to show that Ms. Fearn was discharged for misconduct. The Steeds appealed the decisions of both the DOL and the Commission. Upon consideration of the record and the applicable legal authority, the Supreme Court found that the DOL's and Commission's decisions were supported by substantial and competent evidence. The Court affirmed the decisions. View "Fearn v. Steed" on Justia Law

Plaintiff-Respondent Jeconiah Evans and Defendant-Appellant Jessica Sayler divorced in 2007. They agreed to a joint custody agreement for their two children. Ms. Sayler decided she would go to college and stipulated to a modification of the custody agreement that gave Mr. Evans primary custody of the children. The magistrate court amended the custody order. However, after moving to Washington State, Ms. Sayler did not go back to school and petitioned the court for another change in the custody agreement. The judge held that Ms. Sayler’s decision not to go to college did not constitute a "substantial, material and permanent change" that would warrant another change in custody for the "best interests of the children." On appeal to the Supreme Court, Ms. Sayler argued that the magistrate court abused its discretion by not modifying the custody order. Upon review, the Supreme Court affirmed the magistrate court. The Court found that the magistrate judge’s analysis of Ms. Sayler’s case was consistent with state law, and supported by substantial and competent evidence and was "reached through an exercise of reason." View "Evans v. Sayler" on Justia Law

Petitioner-Appellant Roger Steele and several residents appealed a district court order that dismissed their claim that the City of Shelley (City) illegally annexed land in Bingham County known as "Kelley Acres." The district court found that there was no statutory authorization for the district court's review of the annexation. On appeal to the Supreme Court, Appellants argued that the annexation was "arbitrary and capricious" and procedurally defective. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court found that there was indeed, no statutory authority for judicial review of the annexation. Furthermore, the Court found substantial evidence that supported the City's annexation of Kelley Acres. The Court affirmed the lower court's decision. View "Steele v. City of Shelley " on Justia Law

Plaintiff-Appellant Mary Soignier appealed a district court's decision that granted summary judgment to her former attorney, W. Kent Fletcher. On appeal to the Supreme Court, Plaintiff asserted that Attorney Fletcher negligently drafted a will that failed to "adequately effectuate the testator's intent." After reviewing the record and the applicable legal authority, the Supreme Court found that the district court correctly granted summary judgment to Mr. Fletcher. The Court affirmed the district court's judgment. View "Soignier v. Fletcher" on Justia Law