Justia Idaho Supreme Court Opinion Summaries

Plaintiff-Appellants Franz and Betty Suhadolnik appealed the district court’s grant of summary judgment in favor of their doctor, Defendant-Respondent Scott Pressman. Mr. Suhadolnik argued that his cataract surgeon, Dr. Pressman, failed to adequately inquire about his prior use of a prescription drug that resulted in increased risks during surgery. Mr. Suhadolnik presented expert testimony to demonstrate that Dr. Pressman was negligent when he performed the surgery. The district court determined that Mr. Suhadolnik’s expert failed to address any knowledge of the local standard of care, which was necessary to avoid having the testimony stricken from the trial record. Mr. Suhadolnik appealed to the Supreme Court arguing that the district court erred by dismissing his expert’s testimony. The Supreme Court found that the district court acted within its discretion in holding the expert’s testimony to be inadmissible. Accordingly the Court affirmed the lower court’s holding. View "Suhadolnik v. Pressman" on Justia Law

Petitioner Zack Fields appealed the dismissal of his application for post conviction relief. In 1988, Petitioner was sentenced to death for the stabbing death of Mary Vanderford. Petitioner argued that he was wrongly accused and that DNA test results and affidavits of trial witnesses supported his argument. The district court ordered nineteen latent fingerprints from the murder scene to be run through the national fingerprint database and to have DNA testing of substances found on Petitioner and the victim’s clothing and underneath her fingernails. Testing determined that the fingerprints did not belong to Petitioner, nor did any of the substances contain his DNA. On appeal to the Supreme Court, Petitioner argued that he was entitled to an inference that the victim scratched her attacker because the attacker was close enough to stab her. With no DNA evidence of Petitioner recovered from the murder scene, Petitioner contended the district court erred by not viewing the DNA and fingerprint evidence “in a light most favorable to” Petitioner. The Supreme Court found that there was “nothing but speculation supporting the claim that the scrapings from the victim’s fingernails came from her attacker. We therefore uphold the dismissal of [Petitioner’s] claim . . . because the DNA test results, in light of all admissible evidence, do not demonstrate that [Petitioner] is not the person who committed the murder.” View "Fields v. Idaho" on Justia Law

In October 2008, the Idaho Power Company filed an application with the Idaho Public Utilities Commission (IPUC) to modify its tariff. Some of the proposed amendments applied to the relocation of utilities facilities within public rights-of-way. The City of Nampa and the Association of Canyon County Highway Districts intervened in the proceedings, and each objected to the Company’s proposed amendments to the tariff. The IPUC approved the amendments, and Ada County Highway District (ACHD) filed a petition or reconsideration and clarification. Specifically, ACHD argued that the IPUC exceeded its authority in approving the amendments and that portions of the amended tariff were “an unlawful attempt to amend or abrogate the common law rule requiring a utility to relocate its facilities placed in a public right-of-way at its expense.” Upon review, the Supreme Court found that the IPUC exceeded its authority in determining utilities relocation within public rights-of-way. The Court set aside the amended tariff. View "Ada County Highway Dist. v. Idaho Public Utilities Comm’n " on Justia Law

In October 2008, the Idaho Power Company (Company) filed an application with the Idaho Public Utilities Commission (IPUC) seeking to modify its “line extension” tariff that applied to requests for electrical service that required the installation, alteration, relocation, removal or attachment of company-owned distribution facilities. As homes are constructed in a subdivision, the homeowner requests to be connected to power, and the Company installs wiring from a transformer to the house at no cost to the homeowner. The cost of constructing new distribution facilities had been paid partially from up-front capital contributions from developers, and partially from electric rates charged to all customers. Under the old tariff, the Company gave developers a “line installation allowance” to offset a portion of the developers’ costs in having the Company construct distribution facilities. The allowance was equal to the Company’s cost of providing and installing transformers within the subdivision. Per-lot refunds were refunded to the developer when a permanent residence connected to electrical service and occupied a lot within five years. The per-lot refunds could be as much as $800 each. In this proceeding, the Company sought to change line installation allowances to fixed sums. It also wanted to eliminate the per-lot refunds. The Building Contractors Association of Southwestern Idaho filed a petition to intervene in the proceeding. The Contractors sought to increase per-lot refunds. The IPUC granted the Company’s request to change the line extension allowance to a fixed sum. The Contractors asked the IPUC to reconsider tariff change, but the IPUC denied the request. On appeal to the Supreme Court, the Contractors challenged the sufficiency of the evidence presented by the Power Company to support the tariff change. Finding the evidence sufficient to support the IPUC’s decision, the Supreme Court affirmed the IPUC’s decision to change the power company’s tariff. View "Building Contractors Association of Southwestern Idaho v. Idaho Public Utilities Comm’n " on Justia Law

Plaintiff-Appellant James Wylie owned a subdivision in the City of Meridian. He sought a declaration from the district court that the City and the Idaho Transportation Department improperly denied access for his property directly onto a nearby state highway. The district court dismissed Plaintiff’s complaint on the ground that he failed to present a “justiciable issue.” The Supreme Court’s review of the record revealed that Plaintiff acquired the land in question subject to certain conditions recorded in the plat for the subdivision. The plat listed plainly that “the subject property does have frontage along [the state highway] but . . . not direct access [to the highway].” The Court reasoned that Plaintiff failed to bring an issue for the Court to resolve since Plaintiff’s recorded deed clearly listed the frontage road as access to his property. Therefore, the Court reasoned that the case was “non-justiciable” and affirmed the lower court’s decision to dismiss Plaintiff’s case. View "Wylie v. Idaho Bd of Transportation" on Justia Law

Defendants Milt and Mary Erhart owned a commercial building in Meridian that contained offices that they rented to various lessees. The building had external stairs that consisted of carpet-covered, wooden steps from a ground level landing to the second floor. Mr. Erhart determined that rot made the steps a hazard, and he replaced them with concrete steps in October 2003. Plaintiff Jim Phillips had an office on the second floor. In 2006, Mr. Phillips walked down the stairs to take out the trash when he tripped. He was found lying face-down on the concrete landing at the bottom of the stairs. He suffered various injuries including a closed head injury that caused permanent brain damage and a loss of memory. The Phillipses filed suit against the Erharts in 2007 to recover damages resulting from the fall. A jury returned a verdict for over $1.5 million, finding Mr. Erhart solely at fault for the accident. The Erharts filed motions for a judgment notwithstanding the verdict, for a new trial, and for a remittitur. The district court granted only the remittitur, ordering a new trial unless the Phillipses accepted a reduction in economic damages. The Phillipses accepted the reduction, and the Erharts timely appealed. On appeal to the Supreme Court, the Erharts challenged the sufficiency of the evidence to support finding Mr. Erhart solely at fault for the accident. The Supreme Court found the evidence presented at trial supported the decision of the court and the damages awarded in the case. The Court affirmed the decision of the district court. View "Phillips v. Erhart" on Justia Law

A State trooper arrested Respondent Jason Miller for DUI. The trooper observed that Respondent’s pupils were dilated and asked that Respondent perform some field sobriety tests, which Respondent ultimately failed. The trooper discovered scissors in Respondent’s pocket that were used for cleaning a marijuana pipe. Respondent admitted to smoking marijuana “every day.” The trooper took respondent to a hospital for a urine test, but at the hospital, Respondent refused to willingly provide a sample. A registered nurse at the hospital then catheterized Respondent at the trooper’s request, and extracted the sample. Respondent later pled guilty to possession of drugs, drug paraphernalia and to DUI. Respondent appealed the trial court’s grant of summary judgment to the State. He argued that his civil rights under 42 U.S.C 1983 and state tort laws were violated when he was “unreasonably” catheterized. The Supreme Court found that because “American search-and-seizure law is undeveloped as to when an officer may administer an involuntary warrantless catheterization on a suspect,” the state trooper was entitled to qualified immunity for both of Respondent’s the federal and state law claims. View "Miller v. Idaho State Patrol" on Justia Law

Plaintiffs-Appellants David and Shirley Fuller appealed a grant of summary judgment in favor of Defendants-Respondents David Callister, Confluence Management (CM), LLC and Liberty Partners, Inc. (LP). CM wanted to buy over twelve acres of land from the Fullers. At the same time, the Ada County Highway District (ACHD) attempted to acquire part of that property for a right-of-way in order to expand a portion of a road. After executing its contract with the Fullers, CM executed an addendum to the contract where it agreed to deed over a portion of the property to ACHD, and to transfer the proceeds of that conveyance to the Fullers. CM assigned the contract to LP with the consent of the Fullers. The Fullers executed a warranty deed conveying the property to LP which made no mention of the addendum to ACHD. ACHD paid LP for the property, and the Fullers requested LP turn that money over to them in accordance with the addendum. When LP refused, the Fullers sued. Ultimately CM and LP won at the district court. The court held that the addendum merged with the warranty deed, and therefore gave the Fullers no right to collect the proceeds from the sale of land to ACHD. CM was dismissed from the suit having executed a novation to LP. Upon review, the Supreme Court held that the lower court erred in its decisions in favor of CM and LP. The Court found that the addendum did not merge. Furthermore, the Court found the CM/LP novation was invalid, and that the Fullers could maintain their suit against CM. The Court vacated the district court’s judgment and remanded the case for further proceedings. View "Fuller v. Callister" on Justia Law

A grand jury indicted Defendant-Appellant Daniel Lute for "battery with the intent to commit a serious felony," specifically "rape and/or kidnapping." A judgment of conviction was entered, sentencing Defendant to five years in prison to run concurrently with a sentence Defendant was already serving. The judgment did not specify which serious felony Defendant had intended to commit when he committed the battery. Approximately nine years after the expiration of Defendant's sentence, Defendant filed an ICR 35 motion: the Department of Corrections' records incorrectly showed Defendant had committed a sex crime. Defendant wanted to eliminate confusion. The district court granted Defendant's request, and the judgment was amended to reflect the correct sentence. Five months later, Defendant filed a second ICR 35 motion arguing his sentence was invalid under Idaho law, and that the district court lacked subject matter jurisdiction when it entered the judgment, because the grand jury's term had expired at the time he was indicted. The district court denied Defendant's second ICR 35 motion; the appellate court affirmed. The Supreme Court granted Defendant's petition for review, and found that the district court did not have jurisdiction to convict Defendant when the grand jury indicted him. The Court reversed and remanded the case to the lower court to vacate Defendant's conviction. View "Idaho v. Lute" on Justia Law

Plaintiffs-Appellants James and Lori Mareci brought suit on behalf of their minor son Tristen against Defendant-Respondent Coer D'Alene School District and Defendants Scott and Stevie Kamara. Tristen was injured at school by his classmate Quinton Kamara. On the School District's motion for summary judgment, the Marecis' claims against it were dismissed, and the Marecis appealed. The Marecis' asserted that the School District's staff members were reckless, wanton and willful in how they treated their visibly injured son, and negligent in their supervision of Quinton, who was in their custody. State law limits the liability of a school district when a claim arises out of an injury caused by a person under its supervision, custody or care. On review, the Supreme Court agreed with the lower court's finding insufficient evidence to establish the school district's liability under state law, and affirmed the lower court's decision. View "Mareci v. Coeur D'Alene Sch. Dist." on Justia Law