Justia Idaho Supreme Court Opinion Summaries

Jane Doe appealed a district court’s decision to uphold the magistrate court’s judgment that Doe committed a battery—placing Doe within the purview of the Juvenile Corrections Act. Doe argued the magistrate court erred by using and applying the self-defense law reflected in Idaho Criminal Jury Instructions 1517 and 1518, instead of Idaho Code section 19-202A, Idaho’s “stand your ground” statute. Doe contended the statute’s legal standards differed from Instructions 1517 and 1518, and that the statutory standards should have been applied to her self-defense claim. To this, the Idaho Supreme Court disagreed: the "stand your ground" statute codified aspects of Idaho self-defense law that existed for over 100 years at common law, without abrogating those aspects it left uncodified. Thus, the Supreme Court held the district court did not err in upholding the magistrate court’s use and application of the pattern instructions, which presumptively reflected the elements of self-defense at common law. View "Idaho v. Jane Doe (2021-38)" on Justia Law

Redginald Laren appealed the district court’s denial of his motion for reconsideration following the grant of summary judgment in favor of Krystal Demoney-Hendrickson and the Estate of Cynthia K. Juker. In 1994, Larsen purchased unimproved property in Twin Falls County, Idaho. In 2014, Larsen and Cynthia Juker were in a romantic relationship. Despite participating in an unofficial ceremony resembling a wedding in 2018, the two were never legally married. Shortly after the relationship began, Larsen and Juker moved into a home Juker owned. In 2019, Larsen and Juker entered into a contract to develop his Twin Falls property. About a month later, Juker unexpectedly died. According to Larsen, he and Juker entered into a series of oral agreements around the time they sought financing to improve the Twin Falls property: she would sell her property and they would use the proceeds to pay down the loan for the Twin Falls improvement. In contrast, the Estate contended Juker died intestate and never indicated her wishes for what was to become of her real property. The Estate sold Juker’s property and the proceeds were not applied to the Twin Falls property loan. Both the Estate and Larsen moved for summary judgment on their claims for partition by sale and declaratory judgment. The district court granted the Estate’s motion and denied Larsen’s motion. The Idaho Supreme Court determined the trial court erred in granting summary judgment to the Estate. After ascertaining the parties ownership interests, the Supreme Court determined the trial court had to determine whether partition by sale was warranted. View "Demoney-Hendrickson v. Larsen" on Justia Law

A group of pro se aggrieved property owners dubbed “Riverton Citizens Group,” timely filed a petition for judicial review challenging the Bingham County Commissioners’ (“the County”) decision to grant a zone change request. The caption of the petition named “Riverton Citizens Group” as the pro se petitioner, but the body of the petition then named the aggrieved property owners individually as the parties petitioning the County’s decision, while also providing that they were proceeding pro se under the title of “Riverton Citizens Group.” The petition was not signed by any of the aggrieved property owners. Instead, it was signed by a non-petitioner who purported to be the “agent” for “Riverton Citizens Group.” The purported “agent” was not licensed to practice law in Idaho. After the district court entered a notice of intent to dismiss the petition because Riverton Citizens Group was not represented by counsel, the aggrieved property owners attempted to correct the petition through five subsequent filings, each signed by only one of the aggrieved property owners. The district court subsequently issued a written decision, concluding the petition was “improperly filed” and therefore was not a “petition” that invoked the district court’s subject matter jurisdiction under Idaho Rule of Civil Procedure 84(n). Because the time for filing a new “petition” under I.R.C.P. 84(n) had passed, the district court dismissed the case with prejudice—reasoning it no longer had jurisdiction. A licensed attorney did not appear on behalf of the aggrieved property owners until after the district court’s decision to dismiss. The Idaho Supreme Court vacated the district court’s order: “the errors in the caption and the omitted signatures were not fatal or so defective as to render the petition a nullity or ‘improperly filed’ such that the district court had no subject matter jurisdiction. Instead, these errors may be corrected through a filing or amended petition on remand that relates back to the date of the timely petition.” View "Riverton Citizens Group v. Bingham County Commissioners" on Justia Law

Respondent Camille Pool pleaded guilty to misdemeanor DUI in 2020. In May 2020, approximately two months following the onset of the coronavirus pandemic, Pool was sentenced at a hearing conducted over Zoom which she attended remotely. The State recommended Pool be sentenced to supervised probation with suspended jail time. The magistrate court ultimately sentenced Pool to 180 days in jail with 177 days suspended, granted her a withheld judgment, and placed her on supervised probation for 18 months. The magistrate court went on to explain some of the terms Pool would need to accept in order to receive probation. The following day, the magistrate court entered a written Judgment of Conviction: a form document for DUI cases. A paragraph next to the probation check box listed possible probation terms, which included: "Defendant specifically waives his/her 4th Amendment right to warrantless search of his/her person, vehicle, or residence by any law enforcement or probation officer." The form included a line for the defendant’s signature, but Pool was not personally present in the courtroom and, therefore, did not sign the Judgment. Instead, on the signature line, someone handwrote “mailed to defendant 5/27/2020.” While on probation, Pool failed to appear for drug and alcohol testing and failed to comply with other terms of her probation. On April 14, 2021, three probation officers went to Pool’s residence to conduct a residence check. One officer spoke with Pool, mentioned the Fourth Amendment waiver, and Pool indicated that she understood. Pool’s residence was searched and drugs and drug paraphernalia were found. Pool was charged with felony possession of a controlled substance and a misdemeanor charge for possession of drug paraphernalia. Pool moved to suppress the items seized and the statements she made during the search of her home, arguing that, among other things, she had not waived her right against search and seizure under Article I, section 17 of Idaho’s Constitution and, therefore, the search violated her rights under the Idaho Constitution. The Idaho Supreme Court determined the search was lawful and reversed the district court's decision granting the motion to suppress. View "Idaho v. Pool" on Justia Law

This case concerned a partition action: the district court determined that a physical partition of the property would result in great prejudice and ordered the parties to sell the property and split the proceeds equally. Kay Kiebert appealed the district court’s order, arguing that the district court utilized the wrong standard for determining whether “great prejudice” would result from a physical partition and that it also relied on inappropriate considerations in determining that great prejudice would result. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s order. View "Nordgaarden v. Kiebert" on Justia Law

Appellants Brett and Jenny Terrell appealed a district court’s decision to grant Respondent Paradis de Golf Holding, LLC attorney fees under Idaho Code section 12-120(3). In February 2020, the “Terrells”) sued Paradis for an alleged violation of a recreational easement. In early 2004, Prairie Golf, LLC conveyed to BRMC, LLC a “perpetual, nonexclusive ‘recreational easement’ upon, over, through and across [Prairie Golf’s] property[.]” The easement was appurtenant to and ran with BRMC’s property, which was to be subdivided into 52 single-family residential lots (“the Grayling Estates subdivision”). The easement instrument stated that “each purchaser/owner of a Lot shall be entitled to the benefit of this easement,” which included the ability to play golf for free at a nearby golf course owned at the time by Prairie Golf. In early 2006, the Terrells purchased a home in the Grayling Estates subdivision, which benefitted from the recreational easement. In April 2014, Paradis acquired the golf course subject to the recreational easement. In 2019, Paradis began developing property within the golf course boundary area, which included converting a par five hole to a par three hole and removing a driving range. Paradis then developed residential lots on the excess property where the driving range and part of the par five golf hole used to be. Believing that these developments infringed upon their easement rights, the Terrells sued Paradis. The parties proceeded to arbitration for resolution of their dispute. The arbitrator rendered a decision in Paradis’ favor, finding that none of Paradis’ alterations to the golf course infringed upon the Terrells’ easement rights. Following the arbitration proceedings, Paradis moved for attorney fees under Idaho Code section 12-120(3). The Idaho Supreme Court found the district court erred in concluding that an award of fees was appropriate under section 12-120(3): "Our caselaw is clear that transactions for personal or household purposes do not constitute a commercial transaction for purposes of section 12-120(3)." View "Terrell v. Paradis de Golf Holding, LLC" on Justia Law

Thomas Hooley appealed a district court’s summary dismissal of his petition for post-conviction relief. In 2014, Hooley was convicted of aiding and abetting aggravated battery and kidnapping in the first degree. Hooley petitioned for post-conviction relief in 2019, claiming: (1) he was actually innocent; and (2) the prosecution withheld favorable evidence. The district court concluded that Hooley’s actual innocence claim was time-barred and further concluded the claim failed on the merits. While the district court found that Hooley’s evidence claim was timely, the court ultimately determined the claim failed on the merits, and dismissed the petition without an evidentiary hearing. Finding no reversible error in the summary disposition, the Idaho Supreme Court affirmed the district court. View "Hooley v. Idaho" on Justia Law

Erick Hall appealed the district court’s dismissal of his successive petition for post-conviction relief regarding his death sentence, which he received for the murder of Lynn Henneman in September 2000. Hall contended his appellate counsel had been ineffective for failing to raise certain claims related to the guilt and sentencing phases of his original trial in his first petition for post-conviction relief. Hall further asserted that the district court presiding over the original petition for post-conviction relief committed several reversible errors that appellate counsel failed to raise on appeal to the Idaho Supreme Court. The district court dismissed Hall’s successive petition in its entirety. Finding no reversible error in that decision, the Supreme Court affirmed. View "Hall v. State" on Justia Law

This appeal concerned the existence of an easement across a lot (“Lot 20”) in the Greenbriar Estates subdivision. In 2004, John Esposito acquired two adjacent parcels of land. The northern parcel contained a mini storage unit for use by the residents of the Greenbriar Estates (the “Mini Storage Lot”), while Esposito planned to develop the southern parcel into a recreational vehicle storage lot1 (the “RV Lot”) and to additionally build several more homes. The only access to the planned RV Lot at the time of severance was through the northern parcel. However, no access easement either existed or was created at the time that the northern and southern parcels were severed from the Greenbriar subdivision. Once he completed the development of the subdivision, Esposito quitclaimed the common areas within the subdivision to the Greenbriar Estates Homeowners’ Association (the “HOA”). The HOA subsequently contested Esposito’s use of Lot 20 to access the RV Lot. After Esposito and the HOA began litigating this dispute, the parties entered into two partial settlement agreements: one in 2012 and the second in 2014. In 2013, during the ongoing litigation, Esposito defaulted on his payments for the RV Lot and mortgage-holder D.L. Evans Bank foreclosed. In 2014, Esposito, who no longer owned the RV Lot, settled all existing claims with the HOA in the 2014 total settlement agreement; however, the 2014 agreement did not refer to the RV Lot. Several years later after executing the 2014 settlement agreement, Esposito reacquired the RV Lot from the Bank and resumed his efforts to transform the parcel into RV storage and additional homesites. Once Esposito began developing the RV Lot and using Lot 20 to access it, the HOA again filed suit in district court, alleging Esposito had no right to use Lot 20. The district court granted the HOA’s request to quiet title to Lot 20 but denied the HOA’s request for attorney fees. Esposito and the HOA both appealed the district court’s decisions. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed. View "Greenbriar Estates Homeowners' Association, Inc. v. Esposito" on Justia Law

Darin Ogden appealed his conviction for possession of methamphetamine and drug paraphernalia. During a consensual encounter, officers searched Ogden’s vehicle outside of a business and arrested Ogden for felony possession. At trial, the State introduced redacted police officer on-body video showing the search. The nature and scope of the video became an issue during trial. The jury found Ogden guilty on both counts. At sentencing, Ogden objected to portions of a presentence investigation (PSI) report that included investigative and third-party records from two pending unrelated cases, and seven allegedly inaccurate statements in the PSI. Ogden’s objections to the PSI were largely denied. Ogden appealed to the Court of Appeals, which affirmed, and he then petitioned for review by the Idaho Supreme Court, arguing: (1) a response he gave to officers that was recorded on the video, but redacted, should have been admitted; and (2) it was error for the district court to permit irrelevant evidence to be presented to the jury. Given the accumulation of these alleged multiple errors, Ogden argued that his conviction had to be vacated. The Supreme Court determined district court erred by allowing the State to present evidence that the district court determined was not relevant, but that this error was harmless. "A single error does not require Ogden’s conviction to be vacated." Further, the Supreme Court found the district court abused its discretion in failing to redline the portions of the PSI it had agreed to correct, but did not abuse its discretion in declining to redline portions describing conduct Ogden was acquitted of. The case was remanded to district court to ensure that the victim’s medical records were stricken from the PSI. View "Idaho v. Ogden" on Justia Law