Justia Idaho Supreme Court Opinion Summaries

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

Officers from the Boise Police Department arrested Eduardo Plata Iniguez (“Plata”) outside his home for misdemeanor driving under the influence (“DUI”) without a warrant, and without witnessing the commission of the alleged crime. Upon his arrest, Plata was transported to jail where evidentiary breath testing was administered. At the jail, Plata failed to provide an adequate breath sample. Thereafter, officers procured a warrant from an on-call magistrate judge for a search of Plata’s blood, performed a blood draw at the Jail, and obtained an evidentiary sample of his blood. The State charged Plata with misdemeanor DUI (second offense), and Plata moved to suppress the blood draw evidence as a product of his unlawful arrest under Idaho v. Clarke, 446 P.3d 451 (2019). The Idaho Supreme Court concluded Plata made an initial showing of a causal nexus; Idaho’s exclusionary rule did not include a reasonable “mistake of law” exception; and the State did not argue another established exception applied (e.g., inevitable discovery or attenuation). Thus, the blood draw evidence should have been suppressed as derivative fruit of Plata’s illegal arrest, and the decision of the district court was reversed. View "Idaho v. Plata Iniguez" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on a residence in the Boise foothills that was damaged by a landslide, which ultimately prevented the builder from obtaining a certificate of occupancy. BrunoBuilt, Inc., the general contractor of the project, sued multiple parties, including Erstad Architects, PA, the architectural firm for the project, Andrew Erstad, the principal architect, and Cheryl Pearse, the project manager from Erstad Architects, PA (collectively, Defendants), for professional negligence in connection with work completed for construction of the residence. Defendants successfully moved for summary judgment on the basis that the two-year statute of limitations in Idaho Code section 5-219(4) barred BrunoBuilt’s claim. Two years after the district court issued its memorandum decision and order granting summary judgment, BrunoBuilt moved the district court for reconsideration, citing new evidence and arguments. The district court denied the motion for reconsideration, concluding it was “untimely, lacking in diligence, and improper.” BrunoBuilt then appealed, challenging the decision of the district court on summary judgment and additionally asserting that the court erred in an earlier order deconsolidating the cases with other defendants. Prior to oral argument, Defendants moved the Supreme Court to sanction counsel for BrunoBuilt pursuant to Idaho Appellate Rule 11.2 for non-disclosure of material procedural facts in its opening brief. After review, the Supreme Court affirmed the district court’s decision granting summary judgment against BrunoBuilt, and agreed that the conduct of BrunoBuilt’s attorney on appeal ran afoul of Rule 11.2, and imposed sanctions. View "BrunoBuilt, Inc. v. Erstad Architects, PA" on Justia Law

Kirby Dorff appealed the denial of his motion to suppress evidence obtained after a police drug-sniffing dog jumped onto the exterior surface of his vehicle. Dorff argued the dog’s contact with his vehicle was a trespass, and therefore, an unlawful “search” under the common law trespassory test as articulated in United States v. Jones, 565 U.S. 400 (2012), applied in Idaho by Idaho v. Howard, 496 P.3d 865 (2021) and Idaho v. Randall, 496 P.3d 844 (2021). The Idaho Supreme Court found the drug dog intermeddled with Dorff’s vehicle when it jumped onto the driver side door and window, planted two of its paws, and sniffed the vehicle’s upper seams. Accordingly, law enforcement conducted a warrantless and unlawful “search” of Dorff’s vehicle by way of its drug dog. The denial of Dorff’s motion to suppress was reversed, his conviction was vacated, and this case was remanded to the district court for further proceedings. View "Idaho v. Dorff" on Justia Law