Justia Idaho Supreme Court Opinion Summaries

Police officers responded to a call regarding an individual, McGuire, at a convenience store in Idaho Falls. After determining he was homeless and possibly under the influence, officers took him to a hospital for medical clearance and then to a behavioral health crisis center, where admission is voluntary. When McGuire failed to complete intake paperwork and did not leave when asked, officers attempted to escort him out. A physical altercation ensued, resulting in injuries to both officers. McGuire was charged with felony battery on a law enforcement officer and misdemeanor resisting or obstructing an officer. At trial, the evidence included officer testimony and body camera footage. McGuire did not testify and argued the State had not met its burden of proof.The Seventh Judicial District Court of Idaho denied McGuire’s motion for mistrial, which was based on statements by the prosecutor during closing argument that allegedly shifted the burden of proof to the defendant. The jury found McGuire guilty on both counts. McGuire was sentenced to one year fixed for the felony and fined for the misdemeanor. The Idaho Court of Appeals affirmed both convictions, and McGuire sought further review.The Supreme Court of the State of Idaho reviewed the case, giving due consideration to the Court of Appeals but directly reviewing the trial court’s decisions. The Supreme Court held that there was sufficient evidence to support the conviction for battery on a law enforcement officer, as officers were performing their duties when responding to the crisis center. However, the Court found insufficient evidence to support the conviction for resisting or obstructing an officer, as the State failed to prove the officers’ actions were lawful and authorized under the relevant statute. The Court also held that, although the prosecutor’s comments constituted misconduct, the trial court’s prompt corrective actions and jury instructions cured any resulting error. The Supreme Court affirmed the felony conviction and denial of the mistrial motion, but vacated the misdemeanor conviction. View "State v. McGuire" on Justia Law

A Wyoming limited liability company leased commercial property in northern Idaho to a Delaware corporation, which was formerly known as a North Carolina corporation. The lease required the tenant to pay $1,000,000 annually in rent, increasing by 3% each year, on a triple net basis. During the lease, the tenant made some payments directly to the lender on the property’s mortgage, but these were less than the required rent. Additionally, a related entity paid over $8 million to a contractor for construction of a new residence on the property. The tenant argued that these construction payments should be credited as rent, and that it was not required to pay rent after the first month because the landlord failed to deliver a corporate retreat as allegedly contemplated.The District Court of the First Judicial District of the State of Idaho, Bonner County, granted summary judgment to the landlord for breach of lease, awarding damages and attorney fees. The court found that the tenant failed to pay the full rent required under the lease and rejected the tenant’s argument that construction payments should be credited as rent, finding no evidence of an agreement to that effect. The court also dismissed the tenant’s counterclaim for unjust enrichment, concluding that the lease governed the parties’ obligations and that any improvements became the landlord’s property. The court denied the tenant’s motion for reconsideration, finding no evidence that the tenant funded the construction payments or that such payments were intended as rent.The Supreme Court of the State of Idaho affirmed the district court’s judgment. It held that the district court properly granted summary judgment because there was no genuine issue of material fact regarding the tenant’s failure to pay rent, and no evidence supported the tenant’s claims or affirmative defenses. The Supreme Court also affirmed the award of attorney fees to the landlord and awarded attorney fees on appeal under the lease. View "Erie Properties, LLC v. Global Growth Holdings, Inc." on Justia Law

A Virginia-based company provided tax debt relief services to clients in Idaho, assisting them in negotiating settlements or payment plans for tax debts owed to the IRS and the State of Idaho. The company did not offer services for other types of debt and employed IRS-enrolled agents to represent clients in administrative tax proceedings. Despite conducting substantial business in Idaho, the company did not register as a corporation in the state or obtain a license under the Idaho Collection Agency Act (ICAA). After receiving multiple complaints from Idaho residents about the company’s practices, the Idaho Department of Finance investigated and determined that the company was operating as a “debt counselor” under the ICAA and required a license.The Department initiated an administrative enforcement action, resulting in a hearing officer’s order imposing civil penalties and restitution. The company appealed to the Director of the Department of Finance, who largely upheld the hearing officer’s findings but reduced the restitution amount. The company then sought judicial review in the District Court of the Fourth Judicial District, which affirmed the Director’s final order. The company appealed to the Idaho Supreme Court.The Supreme Court of the State of Idaho held that the company’s activities—negotiating and managing tax debts—fell within the ICAA’s definition of a “debt counselor,” and that unpaid taxes constitute “debt” or “indebtedness” under the Act’s plain language. The Court also found that the ICAA was not preempted by federal law, that the Director did not abuse her discretion in evidentiary or sanction decisions, and that the civil penalties and restitution were supported by substantial evidence. The Court affirmed the district court’s decision and awarded costs, but not attorney fees, to the Department on appeal. View "Wall & Associates, Inc. v. Idaho Department of Finance" on Justia Law

Two men, including the defendant, traveled through Idaho seeking welding work. The defendant owned mobile welding equipment, which he allowed his companion to use for practice in a rural area. After helping set up the equipment, the defendant returned to his truck to nap while his companion welded. During this time, a fire ignited, spreading rapidly and causing significant property damage, including the destruction of homes and grassland. Both men were cited for violating Idaho’s statute prohibiting the willful or careless setting of fires on timber or prairie lands.The case proceeded to trial in the Magistrate Court of Power County, where the State presented evidence that the defendant enabled and facilitated the welding activity in dry, windy conditions, and failed to take adequate precautions to prevent fire. The defendant moved for acquittal twice, arguing that he neither directly ignited the fire nor acted with the requisite criminal negligence. The magistrate court denied both motions, and the jury found the defendant guilty. The defendant was sentenced to a suspended jail term, probation, community service, and restitution. On appeal, the District Court of the Sixth Judicial District affirmed the conviction, finding sufficient evidence of carelessness and upholding the jury instructions.The Supreme Court of the State of Idaho reviewed the case, applying a proximate cause standard to the statutory language “cause to be set on fire.” The Court held that the statute requires proof that the defendant’s actions proximately caused the fire and that he acted with criminal negligence, defined as gross negligence or reckless disregard for the safety of others. The Court found sufficient evidence to support the jury’s verdict under this standard and affirmed the district court’s decision upholding the conviction. View "State v. Frias" on Justia Law

A meat cutter with a long career suffered multiple work-related injuries over the years, including injuries to his back, shoulder, knee, and wrist, but was able to return to full-time, heavy-duty work after each incident. In 2015, he experienced a severe workplace accident in which his dominant right hand was caught in a meat grinder, resulting in the loss of most of his hand and significant impairment. Despite extensive medical treatment, including surgeries and a spinal cord stimulator, he was left with chronic pain and severe functional limitations. He was ultimately found to be totally and permanently disabled and unable to work.After settling with his employer, the claimant sought additional workers’ compensation benefits from the State of Idaho’s Industrial Special Indemnity Fund (ISIF), arguing that his pre-existing impairments, particularly a left wrist injury, combined with the 2015 accident to cause his total disability. The Idaho Industrial Commission held a hearing, considered expert testimony, and found that while the claimant had several pre-existing impairments, only the left wrist injury was a subjective hindrance to employment. However, the Commission concluded that the 2015 meat grinder accident alone rendered him totally and permanently disabled, as his prior injuries had not prevented him from working full-time before that event. The Commission adopted the findings of its appointed Referee and denied ISIF liability.The Supreme Court of the State of Idaho reviewed the case, applying a standard that defers to the Commission’s factual findings if supported by substantial and competent evidence. The Court held that the Commission’s determination was supported by the record, particularly the expert testimony that the 2015 accident, by itself, caused the claimant’s total and permanent disability. The Court affirmed the Commission’s order, holding that ISIF was not liable for any portion of the claimant’s disability. Costs on appeal were awarded to ISIF. View "Westman v. Industrial Special Indemnity Fund" on Justia Law

A religious corporation in Boise owned property that it used for its church activities. The church entered into a Shared Use Agreement with the local YMCA, allowing the YMCA to operate a daycare program on a portion of the property during weekdays. The YMCA paid the church a monthly amount that was below market rent, intended to help cover maintenance expenses. The daycare provided services to working parents in downtown Boise, including those who could not afford to pay full price, and the church considered this partnership part of its mission outreach to the community.The Ada County Board of Commissioners granted the church only an 82% property tax exemption, determining that the portion used by the YMCA was not exempt because it was leased for business or commercial purposes. The Ada County Board of Equalization affirmed this decision after a hearing, and the District Court of the Fourth Judicial District also affirmed, reasoning that the daycare use was not a religious purpose of the church and that the Shared Use Agreement constituted a lease for business or commercial purposes. The district court declined to consider the church’s alternative argument for a charitable exemption because it was not raised in the original application.On appeal, the Supreme Court of the State of Idaho reviewed the statutory requirements for property tax exemptions for religious entities under Idaho Code section 63-602B. The court held that the church’s partnership with the YMCA to provide daycare services was in connection with its religious purposes, as supported by the church’s mission statement and evidence of its outreach activities. The court further held that, although the Shared Use Agreement was a lease, the use of the property for daycare constituted use of recreational facilities and meeting rooms in connection with the church’s purposes, and thus was not a business or commercial purpose under the statute. The Supreme Court of Idaho reversed the district court’s decision and held that the church was entitled to a 100% property tax exemption. View "First Presbyterian Church of Boise, Idaho, Inc. v. Ada County" on Justia Law

The dispute centers on approximately 930 acres of agricultural land owned by two trusts near Pocatello, Idaho. The trusts entered into a purchase and sales agreement with a developer, Millennial Development Partners, to sell a strip of land for a new road, Northgate Parkway, which was to provide access to their property. The trusts allege that Millennial and its partners, along with the City of Pocatello, failed to construct promised access points and infrastructure, and that the developers and city officials conspired to devalue the trusts’ property, interfere with potential sales, and ultimately force a sale below market value. The trusts claim these actions diminished their property’s value and constituted breach of contract, fraud, interference with economic advantage, regulatory taking, and civil conspiracy.After the trusts filed suit in the District Court of the Sixth Judicial District, Bannock County, the defendants moved for summary judgment. The trusts sought to delay the proceedings to complete additional discovery, arguing that the defendants had not adequately responded to discovery requests. The district court denied both of the trusts’ motions to continue, struck their late response to the summary judgment motions as untimely, and granted summary judgment in favor of the defendants, dismissing the case with prejudice and awarding attorney fees to the defendants. The trusts appealed these decisions.The Supreme Court of the State of Idaho affirmed the district court’s denial of the trusts’ motions to continue, finding no abuse of discretion. However, it reversed the grant of summary judgment, holding that the district court erred by failing to analyze whether the defendants had met their burden under the summary judgment standard and appeared to have granted summary judgment as a sanction for the trusts’ untimely response. The Supreme Court vacated the judgment and remanded the case for further proceedings, and declined to award attorney fees on appeal. View "Rupp v. City of Pocatello" on Justia Law

After suffering spinal fractures in a car accident, the plaintiff received surgical treatment and post-operative care from a neurosurgeon and a surgical nurse. The plaintiff was insured at the time, and the medical provider received his insurance information but did not bill the insurer. Instead, the provider filed a medical lien for over $180,000 against any potential recovery the plaintiff might obtain from a third-party tortfeasor, pursuant to Idaho Code section 45-704B. The plaintiff’s attorney objected, arguing that the Idaho Patient Act (IPA) required the provider to bill the patient’s insurance before filing such a lien. The provider maintained the lien was proper under the medical lien statute and did not comply with the IPA.The District Court of the Fourth Judicial District, Ada County, reviewed cross-motions for partial summary judgment. The court determined that the medical lien was not subject to the IPA because it did not constitute an “extraordinary collection action” as defined by the Act. The court also found a factual dispute regarding whether the charges were reasonable, ultimately concluding after a bench trial that the physician’s charges were reasonable but the nurse’s charges should be excluded. The court dismissed the plaintiff’s claims with prejudice, and the plaintiff appealed.The Supreme Court of the State of Idaho reversed the district court’s decision, holding that the medical lien did constitute an “extraordinary collection action” under the IPA because it was a lien placed on the patient’s property in connection with a debt. The Supreme Court further held that, because the provider failed to bill the patient’s insurance before filing the lien, as required by the IPA, the lien was invalid. The judgment was vacated, and the case was remanded with instructions to enter judgment for the plaintiff and declare the lien invalid. The Supreme Court also awarded attorney fees on appeal to the plaintiff. View "DeKlotz v. NS Support, LLC" on Justia Law

The plaintiffs owned three contiguous, landlocked parcels in Ammon, Idaho, with no access to a public road. The property directly south, which bordered an arterial road, was owned by another party. In 2017, the plaintiffs sought to sell their parcels and attempted to purchase an easement from the southern neighbor, but negotiations failed. They then filed suit to establish an easement by necessity over the southern property. The defendants, successors to the original southern owner, raised several affirmative defenses but did not initially cite a statute of limitations.The District Court of the Seventh Judicial District granted summary judgment to the plaintiffs, finding they were entitled to an easement by necessity. On the first appeal, the Idaho Supreme Court held that the four-year statute of limitations in Idaho Code section 5-224 applied to such claims and remanded for fact-finding on when the statute accrued. On remand, the district court found the claim accrued in 2004 and was time-barred, granting summary judgment to the defendants. The plaintiffs appealed, arguing the statute of limitations defense was waived, the summary judgment was erroneous, and the prior Supreme Court decision should be reconsidered.The Supreme Court of the State of Idaho reviewed the case again. It held that the statute of limitations in section 5-224 does not apply to easement by necessity claims, departing from its earlier decision. The court reasoned that such easements arise at severance and exist as long as necessity continues, and applying a statute of limitations would undermine Idaho’s public policy favoring the full use of land. The court vacated the district court’s summary judgment for the defendants, reinstated the original grant of summary judgment to the plaintiffs, and remanded solely to determine the proper location of the easement. The plaintiffs were awarded costs on appeal but not attorney fees. View "Easterling v. Clark" on Justia Law

A 33-year-old man was convicted after engaging in sexually explicit communications and sexual intercourse with a 13-year-old girl, whom he met through messaging apps. The girl’s mother discovered the communications and contacted law enforcement, leading to the man’s arrest after he arrived at a prearranged meeting spot set up by police. Forensic evidence linked the man to the crime. He was charged with lewd conduct with a minor and, following a jury trial, was found guilty and sentenced to life in prison with twenty years fixed.After his conviction, the man appealed his sentence, but the Idaho Court of Appeals affirmed the judgment. He then filed a petition for post-conviction relief, alleging ineffective assistance of counsel. The district court appointed post-conviction counsel but later issued a notice of intent to dismiss the petition for failure to state a prima facie claim. The man did not respond, and the district court dismissed the petition. His counsel filed a notice of appeal. The man, acting pro se, filed several motions, including a motion for extension of time to amend his petition, a motion to remove counsel, and a motion for relief from judgment under Idaho Rule of Civil Procedure 60(b)(6), arguing that his counsel had abandoned him. The district court denied these motions, primarily because the man was still represented by counsel and the motions were procedurally deficient.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in denying the motion for extension of time, finding no extraordinary circumstances or attorney abandonment. The court also affirmed the denial of the Rule 60(b)(6) motion on the unchallenged procedural ground that the motion was not properly noticed for a hearing. The district court’s orders were affirmed. View "Smith v. State" on Justia Law