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Mark Henry Lankford (Lankford) appealed after he was convicted by jury on two counts of felony murder. Lankford and his brother, Bryan Lankford (Bryan), were both convicted and sentenced to death for the 1983 murders of Robert and Cheryl Bravence, who were brutally murdered while camping in the Sheep Creek area of Idaho County. Lankford argued that the district court erred in multiple ways and that he is entitled to a new trial. The State argued Lankford failed to prove that reversible error was committed by the district court and that Lankford’s convictions should be affirmed. After review, the Idaho Supreme Court found that a witness' false testimony about his motive for testifying could have influenced the judgment of the jury. Furthermore, the Court found that the prosecutor's failure to disclose the full details of the agreement for the witness to testify undermined "[its] confidence in the outcome of the trial such that we cannot be sure the defendant 'received a fair trial, understood as a trial resulting in a verdict worthy of confidence.'" Therefore, the Court held Lankford's right to a fair trial was violated and he was entitled to a new one. View "Idaho v. Lankford" on Justia Law

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Appellants Ronald and Margaret Swafford challenged a district court’s grant of summary judgment in favor of Respondent Huntsman Springs, Inc. The action stemmed from the Swaffords’ claim that Huntsman Springs essentially cut off their property from the development by building a park and planting trees between their lot and the nearby street and development, and in doing so: (1) breached a contract; (2) breached an express warranty; (3) breached their duty of good faith and fair dealing; (4) violated the Idaho Consumer Protection Act; and (5) made false representations. The district court granted summary judgment in favor of Huntsman Springs after concluding that all of the Swaffords’ claims were barred by the applicable statutes of limitation. The crux of the Swaffords’ action is that Huntsman Springs breached the Contract by failing to develop the surrounding area in conformance with the Master Plan of the development, i.e., by constructing the park that separated their property from the rest of the development. The Idaho Supreme Court determined the Master Plan was not incorporated or referenced by the Swaffords' Contract; therefore, it did not contractually obligate Huntsman Springs. Accordingly, the Court affirmed the district court's judgment in favor of Huntsman Springs. View "Swafford v. Huntsman Springs" on Justia Law

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Mark Lankford and his brother Bryan were both convicted and sentenced to death for the 1983 murders of Robert and Cheryl Bravence, who were brutally murdered while camping in the Sheep Creek area of Idaho County. Lankford (Lankford) appealed his judgment of conviction, arguing the district court erred in multiple ways and that he was entitled to a new trial. The State argued that Lankford failed to prove that reversible error was committed by the district court and that Lankford’s convictions should have been affirmed. After careful consideration of the evidence presented at trial, the Idaho Supreme Court concluded Lankford was entitled to a new trial based on a finding of prosecutorial misconduct: the prosecutor's failure to disclose the full details of an agreement with a key corroborating witness' testimony “'undermines our confidence in the outcome of the trial,' such that we cannot be sure the defendant 'received a fair trial, understood as a trial resulting in a verdict worthy of confidence.'” View "Idaho v. Lankford" on Justia Law

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Ashley Palmer (Palmer) and Stephen Palmer appealed a district court’s order granting Lisa Ellefson’s motion for a new trial under Idaho Rule of Civil Procedure 59(a)(6). Ellefson was involved in an automobile accident caused by Palmer. A jury found that Ellefson was not injured in the accident. However, the district court determined that the jury verdict of “no injury” was against the clear weight of evidence and granted a new trial subject to an additur in the amount of $50,000. On appeal, Palmer argued that the district court abused its discretion in granting the new trial and in setting additur at $50,000. Finding no such error, the Idaho Supreme Court affirmed. View "Ellefson v. Palmer" on Justia Law

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This case was previously before the Idaho Supreme Court in In Matter of Doe (2016-14), 389 P.3d 141 (2016). There, the Court vacated the judgment terminating Jane Doe’s parental rights to her son M.R. and remanded the case for further findings of fact and conclusions of law. On remand, the magistrate court again terminated Doe’s parental rights. The magistrate court found that M.R. was neglected as defined by Idaho Code sections 16-2002(3)(a) and 16-2002(3)(b) and that Doe’s compliance with her case plan was not impossible. Doe timely appealed. Finding no reversible error, the Supreme Court affirmed. View "H & W v. Jane Doe (2017-3)" on Justia Law

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John Fuquay, Clinton Fuquay, and Hailey Fuquay (the Fuquays), appeal the district court’s grant of summary judgment to Gilbert King, as Trustee of the Heart K Ranch Trust, the Estate of Gordon King, Rose King (the Kings), Susie Low, and Cal Low (the Lows), and the denial of the Fuquays’ motion for reconsideration in a property dispute concerning an alleged prescriptive easement in favor of the Fuquays across the Kings’ and Lows’ property. At various times throughout the year, the Kings grazed cattle over "King Lane." Until 2014, the Kings had barbed wire gates on both the east and west ends of King Lane to enclose their livestock. Anyone attempting to use King Lane had to stop, open, and then close the gates. In 2014, the Kings placed large iron gates across each end of King Lane. The Fuquays purchased their property in 1977. Contrary to Rose King’s testimony, the Fuquays claimed they have continuously used large semi-trucks, cattle trucks, farm vehicles, and personal vehicles to cross King Lane since 1977. In 2014, John Fuquay divided the Fuquay property into parcels for sale. At that time, the Fuquays discovered that there was no recorded easement for the benefit of the Fuquay property for access by way of King Lane. In the summer of 2014, a dispute also arose between the Kings and the Fuquays regarding the iron gates that the Kings placed at each end of King Lane.The district court concluded that because the Kings had annually improved King Lane since 1973 to create an all-weather roadway, the correct presumption was that of permissive use. The district court further concluded the Fuquays failed to present evidence that their use of King Lane interfered in any way with the Kings’ use of the roadway. The district court entered it judgment as to the claims between the Fuquays and the Lows. The Fuquays timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed judgment in favor of the Kings. View "Fuquay v. Low" on Justia Law

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This was a companion case to Green River Ranches, LLC v. Silva Land Company, LLC, Docket No. 43548. In an appeal arising out of Twin Falls County, Appellant Silva Dairy, LLC (“Silva Dairy”), challenged a district court’s holding that Silva Dairy’s claim against Respondent Jack McCall for herd management services was offset by amounts that Silva Dairy owed McCall for feed expenses and pasture rent. McCall owned a livestock business and used Silva Dairy’s herd management services. The district court found that McCall’s total claims against Silva Dairy were at least $492,464.77 and exceeded Silva Dairy’s claim by $287,487.12. Accordingly, the district court dismissed Silva Dairy’s claim with prejudice. Finding no reversible error in this, the Idaho Supreme Court affirmed the district court’s judgment. View "McCall v. Silva Dairy" on Justia Law

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The issue presented in this contract dispute was whether personal jurisdiction was proper over an out-of-state defendant. It centered on two out-of-state companies, one of which, H2O Environmental, Inc. (“H2O”), was registered to do business in Idaho and maintained an office in Boise. H2O filed suit in Idaho against the other company, Proimtu MMI, LLC, alleging breach of contract and seeking reimbursement for the payment of employment taxes for Proimtu employees. Proimtu moved to dismiss for lack of personal jurisdiction and the district court granted the motion. The Idaho Supreme Court found that Proimtu purposefully availed itself of the benefits and protection of Idaho laws. The exercise of personal jurisdiction by Idaho courts over Proimtu was therefore constitutionally proper. View "H20 Environmental v. Proimtu MMI" on Justia Law

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Shawn Wass appealed the judgment entered upon his conditional guilty plea to possession of a controlled substance (methamphetamine). He argued the district court erred when it denied his motion to suppress his admission to the arresting officer that he was in possession of syringes. Wass argued the arresting officer did not inform him of his Miranda rights prior to being questioned. The trial court found the officer did not tactically induce a confession, coerce a confession, or use improper tactics to obtain the confession prior to Miranda warnings. The court found a second set of Miranda warnings did cure the failure to administer it the first time: “[i]t’s not a coercion where the actual circumstances are calculated to undermine the suspect’s ability to exercise free will. So I find that the second Miranda warnings does [sic] cure it. Once that happens, then the officer has reasonable articulable suspicion to search the automobile under the automobile search warrantless exception and he does search it and finds the items found in the case. So I’m denying the motion to suppress.” The United States Supreme Court first addressed the issue of whether admissions made in response to police questioning before Miranda warnings have the effect of rendering the same admissions made again after Miranda warnings inadmissible. Wass did not contend that either his pre- or post-Miranda statements were coerced. Therefore the Idaho Supreme Court upheld the trial court’s decisions that the post-Miranda statements were admissible. View "Idaho v. Wass" on Justia Law

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In 2014, petitioner-appellant Jeremy Wheeler was arrested and charged with possession of methamphetamine. Due to prior convictions of a similar nature, he was also charged with being a persistent violator. Wheeler filed a motion to suppress evidence that was denied by the district court. Consistent with Idaho Criminal Rule 11(e), Wheeler completed a written plea advisory form in 2015. There, he indicated that he was entering a conditional guilty plea, reserving his right to appeal the issue of his “motion to surpress [sic].” He appeared before the district court the next day and entered his guilty plea to the charge of possessing methamphetamine in exchange for dismissal of another criminal matter and the persistent violator allegation. Wheeler was sentenced to serve seven years, with three years fixed, and the district court retained jurisdiction for one year. On August 13, 2015, the district court relinquished jurisdiction at Wheeler’s request. Wheeler’s trial counsel filed a notice of appeal on September 14, 2015, purporting to challenge both the denial of Wheeler’s motion to suppress and his sentence. The State Appellate Public Defender (“SAPD”) was appointed to represent Wheeler on appeal. Wheeler’s SAPD attorney informed him that his appeal from the denial of the motion to suppress was untimely and recommended that Wheeler file a petition for post-conviction relief alleging ineffective assistance of trial counsel for failing to timely appeal from the denial of his motion to suppress. Wheeler filed a pro se petition for post-conviction relief. The State moved for summary dismissal of the petition. The district court granted the motion, finding that Wheeler’s claim that trial counsel had failed to timely appeal the denial of the motion to suppress was groundless. Wheeler timely appealed. The State conceded that the district court erroneously dismissed Wheeler’s petition for post-conviction relief based upon his then-pending direct appeal, and because the Idaho Supreme Court found there was a genuine issue of material fact as to the alternative ground for affirmance posited by the State, the Court vacated the district court’s order dismissing Wheeler’s petition for post-conviction relief and remanded for further proceedings. View "Wheeler v. Idaho" on Justia Law