Justia Idaho Supreme Court Opinion Summaries

Gregory Lowell appealed the Idaho Industrial Commission’s decision affirming the Idaho Department of Labor’s determination that Lowell was ineligible for unemployment benefits because he had been discharged for employee-related misconduct. After review, the Idaho Supreme Court affirmed the Industrial Commission’s decision because Lowell failed to provide a sufficient record or sufficient argument and authority to support his claims. View "Lowell v. Human Dynamics & Diagnostics, PLLC" on Justia Law

Defendant-appellant Robert Miller appealed his conviction for felony driving under the influence (“DUI”) and the district court’s application of a sentencing enhancement based on a prior conviction for felony DUI within the previous fifteen years. On appeal, Miller argued: (1) the district court erred in dismissing the jury before it heard and determined the facts regarding the sentencing enhancement without first obtaining a valid waiver of Miller’s right to a jury trial; (2) the appropriate remedy for the error was to determine the sentencing enhancement did not apply; and (3) if the sentencing enhancement was still applicable to Miller, his sentence should be vacated and the case remanded for a new trial on whether Miller should be subject to the sentencing enhancement. Given the State’s concession that the district court committed fundamental error, the Idaho Supreme Court concluded the appropriate remedy was to vacate Miller’s sentence and remand for a new trial to determine whether the sentencing enhancement applied to Miller. View "Idaho v. Miller" on Justia Law

Defendant-appellant Mark Lankford appealed for the third time his 1983 convictions for the first-degree murders of Robert and Cheryl Bravence near Grangeville, Idaho. Errors in Lankford’s first two trials in 1984 and 2008 resulted in those convictions being vacated. Lankford was retried in 2019 and was again convicted of first-degree murder. Lankford appealed his third conviction, arguing: (1) the district court abused its discretion when it allowed the State to question Lankford’s brother about statements Lankford made on a late-disclosed prison phone recording; (2) the evidence was insufficient to support his conviction when the “law of the case doctrine” is applied to his case; and (3) the district court erred in denying Lankford’s motion to dismiss for a speedy trial violation. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Lankford" on Justia Law

Petitioner-appellant John Bradbury was resident of the City of Lewiston, Idaho and was an elected member of its city council. While serving in that capacity, he filed a petition alleging nine causes of action concerning various City funds and services, including those related to water, sanitation, wastewater, city streets, the library, and the municipally-owned Bryden Canyon Golf Course. Bradbury contended the City had been collecting excessive utility fees and improperly spending municipal funds. Bradbury sought declaratory and equitable relief. He appealed when the district court dismissed most of his claims at summary judgment, and raised additional errors for appellate review. The Idaho Supreme Court determined only that the district court erred in determining that the Idaho Tort Claims Act (“ITCA”) precluded recovery on a constitutional claim seeking equitable relief. The Court determined a remand was unnecessary where Bradbury conceded he was seeking no such remedy for himself. The Court affirmed the district court in all other respects. View "Bradbury v. City of Lewiston" on Justia Law

Brandon Bahr appealed a district court’s summary dismissal of his untimely petition for post-conviction relief. Bahr filed his untimely petition roughly two years after the one-year statute of limitations had expired. The State responded with a motion seeking summary dismissal. Bahr opposed dismissal, arguing the limitations period should have been equitably tolled based on his alleged lack of access to the Idaho courts while transferred to, and incarcerated in, Texas prison facilities. The district court granted the State’s motion for summary dismissal. Bahr argued on appeal to the Idaho Supreme Court that the district court erred by denying him equitable tolling, and by declining to hold an evidentiary hearing concerning whether Bahr lacked access to the Idaho courts while incarcerated in Texas. The Supreme Court affirmed: "Even if Bahr was denied access to the Idaho courts while in Texas, a fact which we have not determined, he is not entitled to equitable tolling because he failed to allege any diligent efforts to pursue his rights while in Texas." View "Bahr v. Idaho" on Justia Law

This appeal concerned the 2008 sale of real property located in Twin Falls, Idaho owned by the partnership White, White & Lawley I (“WWLI”), which sold the Property to White X Three, LLC, for $650,000. In 2009, after White X Three acquired and then substantially renovated the Property, it began to lease the Property. At the time of the sale, Xantha White, then a minor child, and Todd White, her uncle, each held a one-half interest in the White Family Trust. The White Family Trust was a one-third partner in WWLI when it sold the Property. Todd was also a member of White X Three, placing him on both sides of the sale and purchase of the Property. Although he had a conflict of interest in the sale, Todd did not obtain court approval for the sale pursuant to Idaho Code section 68-108(b), nor did he inform Xantha or her mother, who was also Xantha’s conservator, of the sale. Xantha (now known as Xantha Darrow) and the Trustee of the Xantha J. White Trust, Larry Braga, brought suit against Todd and White X Three, asserting that, because Todd did not obtain court approval for the sale of the Property, the sale was void and the Property should be placed in a constructive trust. Both parties moved for summary judgment. The district court granted partial summary judgment in favor of Todd and White X Three, concluding that the sale of the Property was not void because Idaho Code section 68-108(b) did not apply. The district court also declined to place the Property in a constructive trust but allowed Xantha's claim of breach of a fiduciary duty to continue. Xantha thereafter moved for an Idaho Rule of Civil Procedure 54(b) certification to allow her to appeal the partial judgment rendered against her. The district court granted her request, and this appeal followed. The Idaho Supreme Court found the district court erred in determining there was no issue of material fact that Todd complied with the terms of the Trust Indenture in consenting to the sale of the Property, both in general and in terms of the sale price. Further, the Supreme Court concluded the district court erred in declining to place the Property in a constructive trust. The case was remanded for further proceedings. View "Darrow v. White" on Justia Law

Robert Houston created a trust which, after amendments, created three separate subtrusts designed to become effective following Robert’s death: a “Marital Trust,” a “Grandchildren’s Trust,” and a “Residuary Trust.” Within the Residuary Trust, Robert created two "for the benefit of" ("FBO") trusts, one for each of Robert’s children, Patricia and Richard. A clause in the FBO Richard Trust granted Richard a testamentary power of appointment to direct how Richard’s share of the Residuary Trust would be distributed if Richard predeceased Robert’s then-wife Lyn. The Marital Trust separately provided that if Richard was not alive when the Marital Trust assets were distributed, Richard’s portion of the Marital Trust would be placed in a “Grandchildren’s Trust” to benefit Richard’s two children from his first marriage (Robert and Lyn’s grandchildren) Ryan Houston and Crystal Siegler. This matter was litigated in Richard’s probate case after his death. Before the magistrate, Richard’s second wife and the personal representative of his estate, Susan Marie Houston, claimed that Richard assigned his interest in Robert’s trusts to her in Richard’s will. Ryan and Crystal argued that because their father, Richard, had not yet inherited from their grandfather’s trusts before he died, Richard could not assign those interests to Susan. The magistrate court agreed with Susan and held that Richard validly assigned his interests to her. Ryan and Crystal, as potential beneficiaries of the Grandchildren’s Trust, appealed that decision to the district court, which reversed the magistrate’s decision. Susan appealed, arguing that the district court erred by converting the intermediate appeal to a trial de novo and by concluding the magistrate court’s interpretation of Robert’s Trust was unreasonable. After its review, the Idaho Supreme Court found no reversible error in the district court's decision and affirmed. View "Houston v. Houston" on Justia Law

The Idaho Industrial Commission issued an order denying Veronica Arreola’s petition for a declaratory ruling and motion for reinstatement of compensation. Arreola brought her petition and motion against the Granite State Insurance Co. (“the Surety”), when the Surety, without an order from the Commission invoked I.C. section 72-434 to suspend Arreola’s compensation payments. In the Surety’s unilateral and private determination, suspending Arreola’s compensation payments was appropriate because the Surety had purportedly scheduled Arreola’s Independent Medical Exam (“IME”) with its physician at a “reasonable” time, and Arreola “unreasonably” failed to submit to or had obstructed the scheduled IME by not appearing. Arreola’s petition and motion disputed these private conclusions by the Surety. Arreola also maintained that only the Commission has the authority to adjudicate the underlying medical exam dispute and determine whether there is a factual basis to execute the enforcement mechanisms in Idaho Code section 72-434. The Commission denied the petition and motion, instructing Arreola to instead proceed through a complaint for relief. The Idaho Supreme Court concluded its decision in Brewer v. La Crosse Health & Rehab, 71 P.3d 458 (2003) interpreting Idaho Code section 72-434 was manifestly wrong. "Only the Commission has the authority to adjudicate medical exam disputes, and to enforce that adjudication through the enforcement mechanisms in section 72-434." In light of this, Arreola’s concern that the Surety’s unilateral execution of the enforcement mechanisms in section 72-434 also suspended her right to file a “complaint” to seek relief was now abated. Nevertheless, the Supreme Court did not affirm: given the shift in the legal landscape with Brewer overruled, the Commission’s order denying the petition and motion was vacated, and the case remanded with instructions that the Commission: (1) order payment of prospective compensation payments that might be owed until such time as the Commission determines that payments are not required under section 72-434; (2) reconsider the appropriate procedural mechanism for adjudicating the underlying factual dispute; and (3) instruct the Surety what procedural mechanism it must use to obtain an order authorizing it to lawfully suspend compensation payments. View "Arreola v. Scentsy, Inc." on Justia Law

This case stemmed from a 2019 lease by Respondents the City of Sandpoint (“the City”) to The Festival at Sandpoint (“The Festival”), a nonprofit corporation, to operate a multi-day music concert series in War Memorial Field Park. The Festival had a long-standing policy of prohibiting festival patrons from bringing weapons, including firearms, into the event. On August 9, 2019, Scott Herndon and Jeff Avery purchased tickets to the festival and attempted to enter. Avery openly carried a firearm and Herndon possessed a firearm either on his person or in a bag (the record was unclear on this point). Security personnel for the event denied entry to both. After discussions with a City police officer and the City’s attorney, who was coincidentally attending the same event in his private capacity, Herndon and Avery eventually left the music festival and received a refund for their tickets. Appellants Herndon, Avery, the Idaho Second Amendment Alliance, Inc., and the Second Amendment Foundation, Inc. subsequently sued the City and The Festival, asserting several claims, including seeking injunctive relief prohibiting the Respondents from violating the Idaho and United States Constitutions, particularly the Second Amendment and the Idaho Constitution’s provision securing the right to keep and bear arms in public for all lawful purposes. The district court ultimately granted the Respondents’ motions for summary judgment, awarded both the City and The Festival attorney fees and costs, and dismissed all the Appellants’ claims with prejudice. The issue raised on appeal was whether a private party who leased public property from a municipality may govern those who come and go from the property during the lease. The Idaho Supreme Court responded in the affirmative, and affirmed the district court's judgment. View "Herndon v. City of Sandpoint" on Justia Law

Jay Wright appealed the district court’s grant of summary judgment to his ex-wife, Kristie Parish. Wright and Parish were married in 2002 and divorced in 2019. Before they were married, Wright and Parish, as single persons, purchased two adjacent parcels of real property in Island Park, and their ownership of the property did not change following their marriage. A magistrate court presided over their divorce proceedings and the distribution of their community property. The magistrate court classified as community property certain loan payments and improvements that had been made for the benefit of the Island Park Properties but specifically declined to divide the properties because the court concluded the properties were separate property and that it “lack[ed] authority to divide the property.” The magistrate court concluded that Wright and Parish “apparently” owned the properties as tenants-in-common, each with a fifty percent interest, though it never made a definitive ruling on each party’s interest, concluding only that they were “joint owners[.]” Roughly one year after the magistrate court entered its final judgment for the divorce, Wright filed suit seeking a partition of the Island Park Properties and for Parish to deed them to him, arguing in part that his ownership interest in the properties exceeded the fifty percent determination that the magistrate court had ostensibly made. In response, Parish moved for summary judgment, arguing that Wright’s claim that he was entitled to a greater ownership interest was precluded by the doctrines of res judicata and collateral estoppel. The district court granted Parish’s motion for summary judgment after determining that the issues in Wright’s complaint had already been litigated in the prior divorce proceedings. As a result, the district court concluded that the proceeds from the sale of the properties should be equally divided between Wright and Parish. Wright appealed. The Idaho Supreme Court determined the district court erred in granting summary judgment to Parish, and remanded the case for the trial court to consider whether Wright could produce evidence to overcome the rebuttable presumption of equal ownership in the properties. View "Wright v. Parish" on Justia Law