Justia Idaho Supreme Court Opinion Summaries

In 2017, Guy Bracali-Gambino pleaded guilty to possession of major contraband in a correctional facility. On direct appeal, the Idaho Court of Appeals, in an unpublished opinion, affirmed his conviction and sentence. Bracali-Gambino subsequently filed a petition for post-conviction relief, arguing in relevant part that his trial counsel had coerced him into pleading guilty, provided erroneous legal advice regarding sentencing enhancements for persistent violators, and failed to investigate the prosecution’s evidence. Bracali-Gambino contended, that considering these errors, his trial counsel had been ineffective. Except for a portion of one of Bracali-Gambino’s claims (Claim II), the district court summarily dismissed his claims relevant to this appeal without conducting an evidentiary hearing. The district court also ultimately dismissed the one remaining claim following an evidentiary hearing. The Idaho Supreme Court affirmed the district court’s dismissal of Bracali-Gambino’s petition for post-conviction relief. Claim II failed because Bracali-Gambino specifically disclaimed, while under oath at his change of plea hearing, that anyone (which included his defense counsel) had coerced or pressured him into pleading guilty. Claim III failed because Bracali-Gambino’s conclusory allegations were not sufficient to show that he was prejudiced by the purported erroneous legal advice. Finally, Claim VI failed because Bracali-Gambino did not provide a sufficient explanation as to how certain testimony would have contradicted the State’s evidence that he attempted to possess major contraband. View "Bracali-Gambino v. Idaho" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on a wage claim dispute between Pat Stiffler and his previous employer, Hydroblend, Inc. After a dispute arose concerning incentive pay on an allegedly miscoded account, Stiffler filed a complaint for unpaid wages, breach of contract, retaliation, and wrongful termination. The proceedings culminated with two orders from the district court that: (1) awarded summary judgment to Hydroblend concerning treble damages; (2) concluded multiple issues were governed by an arbitration provision in Stiffler’s employment agreement; and (3) denied summary judgment where disputed facts remained at issue. Stiffler appealed the district court’s decisions, arguing that he is entitled to treble damages on all wages under Idaho’s Wage Claim Act, as well as severance pay under his 2019 employment contract. Stiffler also argues that the district court erred by compelling arbitration of some of his claims. The Idaho Supreme Court reversed the district court’s dismissal of Stiffler’s arbitrable claims because they should have been stayed, not dismissed. However, the Court affirmed the district court’s determination that a 2019 Contract controlled the issue of incentive pay while the remaining claims arose under a 2021 Contract and its arbitration agreement. As the prevailing party, Hydroblend was entitled to costs on appeal pursuant to Idaho Appellate Rule 40(a). View "Stiffler v. Hydroblend, Inc." on Justia Law

Shake Out, LLC entered into a contract with Clearwater Construction, LLC (“Clearwater”), to repair the building Shake Out’s restaurant occupied. The relationship between the parties quickly deteriorated, resulting in Shake Out filing a lawsuit against Clearwater. The parties attempted to mediate their dispute but were unsuccessful. After the case had proceeded for some time, Clearwater sought to compel arbitration pursuant to the contract. Shake Out objected, asserting that Clearwater had waived its right to enforce the arbitration clause because it had participated in the litigation for almost ten months before seeking to compel arbitration. The district court concluded Clearwater had not waived its right to seek arbitration and entered an order compelling arbitration and staying the proceedings. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "Shake Out, LLC v. Clearwater Construction, LLC" on Justia Law

Appellant North West Neighborhood Association challenged a district court’s decision upholding Boise City Council’s approval of three interrelated land use applications. The Idaho Supreme Court agreed with Appellant that Boise City Council failed to provide a reasoned statement explaining its approval of the applications as required by section 67-6535(2) of the Local Land Use Planning Act. The Court remanded this matter to the district court with instructions to set aside Boise City Council’s actions and remand to the Council for the adoption of a reasoned statement. View "NW Neighborhood Assoc v. City of Boise" on Justia Law

Holly Rich brought a legal malpractice action against her attorneys, Hepworth Holzer, LLP, and E. Craig Daue and Daue Buxbaum, PLLC (“Daue Buxbaum”) (collectively, “Respondents”), regarding their legal representation of Rich in an underlying medical malpractice action against Eastern Idaho Regional Medical Center (“EIRMC”), Dr. John Lassetter (a cardiologist), and Dr. Charles Phillips (an intensivist) (collectively, “EIRMC providers”). In that action, Rich's claims against the EIRMC providers failed because they were filed after the statute of limitations expired. Rich alleged in this action that those claims were not filed on time because of Respondents’ legal malpractice. Both sides filed substantive motions for summary judgment and the district court found that Rich could not prevail because she had “not disclosed any expert [medical] testimony which complies with the requirements of Idaho law for admissibility.” The district court concluded that, lacking evidence to “set out a prima facie case of medical malpractice,” in the underlying case, Rich’s claim against Respondents for legal malpractice failed. Rich appealed. The Idaho Supreme Court found no reversible error and affirmed. View "Rich v. Hepworth Holzer" on Justia Law

This lawsuit arose from an investigation into whether Appellant Kristine McCreery abused or neglected her fifteen-year-old son, B.M. McCreery filed a complaint against two physicians who reported the alleged abuse, the detective who investigated the reports, the deputy prosecutor who filed the Child Protection Act (“CPA”) action, and the social worker for the Idaho Department of Health and Welfare who submitted an investigatory report and testified in the CPA case (collectively “defendants” or “Respondents”), alleging they had violated her constitutional rights and Idaho’s false reporting statutes when they took actions to separate her from B.M. for over fifteen months. The district court dismissed McCreery’s claims with prejudice after finding Respondents were immune from liability and that the allegations in McCreery’s complaint failed to state any valid claim upon which relief could be granted. McCreery moved to amend her complaint, which the district court denied. McCreery appealed to the Idaho Supreme Court, arguing that the district court erroneously dismissed her claims. The Supreme Court found no reversible error and affirmed. View "McCreery v. King, M.D., et al." on Justia Law

After methamphetamine was found on his person during a pat search, Appellant John Doe was charged with felony possession of a controlled substance and two related misdemeanors under the Juvenile Corrections Act (“JCA”). Doe moved to suppress this evidence as the product of an unlawful search under the Fourth Amendment, which the magistrate court denied. Doe then sought permission to appeal the magistrate court’s decision to the district court, sitting in its intermediate appellate capacity. When the magistrate court denied permissive appeal, an intermediate appeal was filed with the district court. The district court dismissed Doe’s appeal, concluding that a permissive appeal was not available to Doe because he had not yet been adjudicated of any violation under the JCA. Doe then appealed to the Idaho Supreme Court, arguing: (1) he was “within the purview” of the JCA; and (2) Idaho Code section 20-528 permitted an appeal as a matter of right to a juvenile defendant whose motion to suppress has been denied. The Idaho Supreme Court concluded the plain language of the statute did not permit a juvenile defendant to file this type of interlocutory appeal. Accordingly, the Court affirmed the district court’s dismissal of John Doe’s interlocutory appeal. View "Idaho v. John Doe" on Justia Law

An Idaho district court denied Jared Head’s motion to strike certain evidence supporting a restitution order. Jared and his wife, Teresa, worked as onsite managers at the Village Inn Motel in Malad City, Idaho. Following an investigation by the Oneida County Sheriff’s Office, Jared and Teresa were separately charged with grand theft. After pleading guilty to grand theft, Jared was ordered to pay $24,535.23 in restitution for allowing people to stay at the motel without paying, and for accepting rent payments that he did not relinquish to the motel owners. Relevant to this appeal, some of the State’s evidence supporting the restitution amount related to a specific hotel guest, S.G. Just before resting its case at the restitution hearing, the State disclosed that S.G. had been found incompetent to stand trial in an unrelated criminal case several months earlier. Jared then sought to strike any testimony, exhibits, and statements related to S.G., arguing the State withheld exculpatory evidence in violation of his due process rights under Brady v. Maryland, 373 U.S. 83 (1963) and in violation of his Sixth Amendment right to confrontation under Crawford v. Washington, 541 U.S. 36 (2004). The district court denied Jared’s motion after concluding that his due process claim was moot because Brady did not apply to restitution hearings, which the district court couched as civil proceedings. Jared appealed, arguing the district court erred in applying an incorrect legal standard to deny his motion to strike. Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Idaho v. Head" on Justia Law

In 2019, Matt Dorsey brought an action against his father, Tom Dorsey, seeking formal accounting, dissolution, and winding up of their joint dairy operation, Dorsey Organics, LLC. The district court appointed a Special Master; the Special Master subsequently recommended to the district court that it grant partial summary judgment to Tom on Counts Four (breach of contract) and Five (constructive fraud). Without receiving a definitive ruling from the district court on the recommendations regarding the motions for summary judgment, the case then proceeded to a four-day hearing presided over by the Special Master, which resulted in the Special Master making Proposed Findings of Fact and Conclusions of Law. The district court adopted, with almost no changes, the Special Master’s Proposed Findings of Fact and Conclusions of Law, which relied upon the accounting of Tom's expert and rejected the opinions of Matt's expert. The district court then entered a judgment incorporating, with few changes, the Special Master’s Proposed Findings of Fact and Conclusions of Law. The district court also denied Tom's request for attorney fees. Matt appealed, arguing: (1) the district court failed to properly review the evidence before accepting the findings of the Special Master; (2) questioned whether a court could override the terms of a contract even though the contract’s terms arguably produced an inequitable result; (3) Tom wrongfully dissociated from Dorsey Organics prior to its dissolution and the winding up of its affairs; and (4) challenged whether summary judgment was properly granted on Counts Four and Five of the Third Amended Complaint. The Idaho Supreme Court concluded the district court erred in failing to independently review the record before adopting the Special Master's Proposed Findings of Fact and Conclusions of Law. Accordingly, the Court vacated the district court's conclusions that relied on the Special Master's findings. The case was thus remanded for further proceedings. View "Dorsey v. Dorsey" on Justia Law

A large, dead tree near a mobile home rented by Tammy and Thomas Sankey fell and damaged the Sankeys’ vehicles, killed one of their cats and traumatized the other, and caused Tammy Sankey to experience emotional distress. Proceeding pro se, the Sankeys filed a small claims action against the owner of the mobile home park where they lived and the owner and managers of their mobile home. After losing in small claims court because they failed to prove on whose land the offending tree was located, the Sankeys filed for a trial de novo in magistrate court and paid for a land survey. The Sankeys submitted both documents attached to a joint declaration from them in opposition to motions for summary judgment filed by the owners and managers, along with a declaration from the Sankeys’ neighbor setting forth the neighbor’s lay testimony that the tree was located on the lot occupied by the Sankeys. The owners and managers of the mobile home and the mobile home park filed motions to strike the declaration from the neighbor as well as portions of the Sankeys’ declaration and the attached Record of Survey and Tree Exhibit. The magistrate court granted the motions, holding that no foundation had been laid for the Record of Survey and Tree Exhibit and that they were inadmissible hearsay. The magistrate court also struck the declaration of the neighbor because her testimony about the location of the fallen tree was not based on her personal knowledge. Without admissible evidence of who owned the land where the fallen tree was located, the magistrate court granted summary judgment in favor of the owners and managers. The magistrate court denied the Sankeys’ motion for reconsideration. The district court, sitting in its appellate capacity, affirmed the magistrate court’s decision. Finding no reversible error, the Idaho Supreme Court affirmed the decision of the district court. View "Sankey v. Ivey" on Justia Law