Justia Idaho Supreme Court Opinion Summaries

John Doe sought custody of his daughter, Jane Doe, who was removed from the care of her mother in Idaho when a child protection action was initiated by the Idaho Department of Health and Welfare (“IDHW” or “the Department”). Jane Doe and her maternal half-brother were removed from the custody of their mother in December 2020 due to allegations of abusive conduct. Jane Doe had previously been removed from her mother’s custody in 2018 due to substance abuse issues. John Doe lived in Texas with his wife, who was Jane Doe’s stepmother, and their child, Jane Doe’s paternal half-sibling. At the time of the removal, John Doe was considered a “non-offending parent.” However, the initial “Adjudicatory/Disposition Report of Investigation” filed with the magistrate court noted that John Doe was listed on the Texas Public Sex Offender Website. The magistrate court exercised jurisdiction over Jane Doe in early 2021 and placed her in the Department’s legal custody. As part of the case plan for John Doe, the magistrate court ordered John Doe “to comply with and complete the approval with the [Interstate Compact on the Placement of Children (“ICPC”)] process with the state of Texas[,]” to assess the suitability of John Doe as a placement option for Jane Doe. The ICPC process ordered by the court included a home study and a placement determination. Texas denied IDHW’s multiple requests to conduct a home study on John Doe due to John Doe’s history, which included two prior sex offenses and a past child protection order, along with allegations of physical abuse, sexual abuse, negligent supervision, physical neglect, and medical neglect. Texas also noted that John Doe was a registered sex offender who had previously failed to register. As a result, John Doe never completed a home study. John Doe thereafter requested the Idaho magistrate court revise its case plan to strike the requirement he complete the ICPC process. This request was denied, and the issue before the Idaho Supreme Court in this matter centered on whether the ICPC even applied to John Doe as an out-of-state, non-custodial parent. The Supreme Court affirmed the magistrate court’s order modifying the case plan and held that by its plain language, the ICPC did not apply to an out-of-state, non-custodial parent. View "IDHW v. John Doe (2022-32)" on Justia Law

This case arose from a medical malpractice action involving a partial foot amputation and sentinel lymph node biopsy (“SLNB”). John Beebe was diagnosed with aggressive melanoma on his foot. After his diagnosis, oncology specialists recommended a forefoot amputation and a SLNB. The SLNB involved the removal of a lymph node near John’s stomach to assist the oncologist with staging the cancer. Both procedures were performed at North Idaho Day Surgery, LLC, d/b/a Northwest Specialty Hospital (“NWSH”), after which the removed forefoot was placed into a pathology specimen bag and the lymph node was placed in a specimen cup. Purportedly, both specimens were subsequently placed in a second sealed bag, which was then placed in a locked drop box at NWSH for pickup by Incyte Pathology, Inc. Two days after the surgeries, NWSH received notice from Incyte that the lymph node was missing. NWSH subsequently searched the operating rooms, refrigerators, and the dumpster, but did not find the missing specimen. The Beebes filed a complaint against NWSH for medical malpractice and negligence and against Incyte for simple negligence. They later amended their complaint to add Cheryl’s claim for loss of consortium. The Beebes appealed the jury verdict in favor of NWSH, arguing the district court erred when it granted summary judgment for NWSH and dismissed Cheryl’s loss of consortium claim prior to trial. The Idaho Supree Court vacated the jury verdict because the district court gave a “but for” jury instruction on the issue of proximate cause instead of a “substantial factor” instruction. Further, the Supreme Court reversed and remanded the district court’s grant of summary judgment and dismissal of Cheryl’s loss of consortium claim. View "Beebe v. North Idaho Day Surgery, LLC" on Justia Law

Christine and Thomas O'Holleran married in 2005. They had no children. In 2015, Christine filed for divorce and in her complaint alleged “[t]hat [Thomas] is guilty of physical and mental abuse toward [Christine], and such is sufficient that this marriage should be terminated at the fault of [Thomas].” In his response and counterclaim, Thomas requested a divorce on the grounds of habitual intemperance, extreme cruelty, and irreconcilable differences. Christine subsequently moved to amend her divorce complaint to add a tort claim for emotional and physical abuse and requested damages in excess of $10,000. In his answer to Christine’s amended complaint, Thomas asserted an affirmative defense arguing that the magistrate court lacked jurisdiction to hear Christine’s tort claim. The magistrate court granted Christine’s motion to amend her complaint. The magistrate court held a bench trial on the claims asserted in the Amended Complaint, granting the divorce on grounds of irreconcilable differences, divided the parties’ real and personal property, and awarded Christine spousal maintenance. The decision did not address Christine’s tort claim. Thomas and Christine both filed motions to reconsider, but neither mentioned the magistrate court’s lack of findings and conclusions regarding Christine’s tort claim. Similarly, the magistrate court did not address Christine’s tort claim in its order denying reconsideration. The issue on appeal to the Idaho Supreme Court was whether the magistrate court had authority to decide a tort claim by one spouse against another as an ancillary matter to a divorce proceeding. The Supreme Court determined Idaho Code sections 1-2208 and 1-2210 and I.C.A.R. 5 limited the case types that could be assigned to magistrate courts to those specified in the Seventh Judicial District’s order on local rules. That order did not give the magistrate court authority to decide civil cases seeking damages in excess of $10,000. Nor was the tort claim an ancillary matter to the divorce proceeding. Accordingly, the district court erred when it determined the magistrate court had authority to decide Christine’s tort claim. View "O'Holleran v. O'Holleran" on Justia Law

Treasure Valley Home Solutions, LLC, (“TVHS”) filed a complaint against Richard Chason alleging breach of contract and requesting specific performance of a real estate purchase contract after Chason refused to move forward with the transaction. Chason moved for summary judgment, arguing the Agreement lacked definite terms and was therefore unenforceable. The district court granted Chason’s motion for summary judgment after concluding the Agreement was a mere “agreement to agree.” The district court also awarded Chason attorney fees. TVHS appealed both orders. The Idaho Supreme Court concluded after review that the district court did not err when it granted Chason’s motion for summary judgment because a valid contract was never formed between the parties. However, the district court erred when it awarded Chason attorney fees pursuant to Idaho Code section 12-120(3) because the evidence did not establish that a commercial transaction was the gravamen of the claim between TVHS and Chason. Neither party was awarded attorney fees or costs on appeal. View "Treasure Valley Home Solutions, LLC v. Chason" on Justia Law

Jonathan Hernandez pled guilty to second-degree murder. He petitioned for post-conviction relief, arguing his trial counsel was ineffective for promising Hernandez he would not receive a sentence of more than ten to fifteen years. Following this alleged promise from his attorney, Hernandez signed a written plea agreement and guilty plea advisory form. At the change of plea hearing, the district court placed Hernandez under oath and confirmed that Hernandez and his attorney had reviewed the guilty plea advisory form. The district court later sentenced Hernandez to a unified term of life in prison, with a minimum period of confinement of forty-five years. Following an unsuccessful appeal, Hernandez petitioned for post-conviction relief. At the hearing on the State’s motion for summary judgment, the district court found that any error Hernandez’s counsel made was cured by a colloquy that took place between the district court and Hernandez at the change-of-plea hearing. There, the district court confirmed answers Hernandez gave on the plea agreement form and the potential sentence Hernandez faced. The district court granted the State’s motion for summary judgment and dismissed Hernandez's case with prejudice. Finding no reversible error in the dismissal of Hernandez's petition for relief, the Idaho Supreme Court affirmed the district court. View "Hernandez v. Idaho" on Justia Law

Jorge Rodriquez was convicted of domestic battery with traumatic injury in the presence of a child. His first trial ended with a hung jury. In the second trial, the jury found Rodriquez guilty of the charge. The district court sentenced Rodriquez to eighteen years, with eight years determinate. Rodriquez directly appealed his conviction, and the Idaho Court of Appeals affirmed. Rodriquez then petitioned for post-conviction relief alleging ineffective assistance of counsel, prosecutorial misconduct, and the denial of his right to a fair trial following various rulings from the district court. After reviewing his petition, and several dispositive filings, the district court served Rodriquez with a notice of intent to dismiss on October 6, 2020. Rodriquez amended his petition the next day, and the district court served Rodriquez with its second notice of intent to dismiss on October 15, 2020. Rodriquez filed a supplemental brief five days after his response was due. The district court dismissed the petition after concluding Rodriquez failed to timely respond. Rodriquez appealed to the Idaho Court of Appeals, which affirmed. Rodriquez then petitioned for review to the Idaho Supreme Court, which was granted. Finding no reversible error, the Supreme Court affirmed the district court’s judgment summarily dismissing Rodriquez’s petition. View "Rodriquez v. Idaho" on Justia Law

Prior to voir dire in George Cuenca’s trial for aggravated battery, taking place in the midst of the COVID-19 pandemic, the district court ordered that everyone in the courtroom would wear masks, including witnesses. Cuenca objected that the jury would be unable to assess the witnesses’ facial expressions and demeanor during their testimony, which would make it difficult for the jury to judge the credibility of the witnesses. The district court overruled the objection. The trial proceeded, and the jury found Cuenca guilty. Cuenca appealed, claiming his confrontation right was violated by the district court’s mask order. After review, the Idaho Supreme Court concluded the district court’s order did not violate Cuenca’s confrontation right, and affirmed his judgment of conviction. View "Idaho v. Cuenca" on Justia Law

Wayne Marsh was detained by police after an informant reported witnessing an attempted burglary and described him to dispatch as one of the two suspects. During the investigatory detention that ensued, police discovered a valid, outstanding arrest warrant for Marsh. When a subsequent search incident to Marsh’s arrest was performed, the police found methamphetamine in his pocket. After he was charged with possession of a controlled substance, Marsh moved to suppress this evidence, which the district court denied. On appeal, Marsh argued the informant’s tip did not provide reasonable suspicion to justify the initial warrantless detention because it lacked adequate indicia of reliability. He also argued that the alternative basis for the district court’s ruling, that discovery of the arrest warrant attenuated any illegality of his initial detention, was incorrect because of the heightened protections contained in the Idaho Constitution. Finding neither of these arguments persuasive, the Idaho Supreme Court affirmed the district court's order. View "Idaho v. Marsh" on Justia Law

Gilberto Roman-Lopez was convicted by jury on two counts of sexual abuse of a child and three counts of lewd conduct with a minor. Roman-Lopez argued the Idaho Supreme Court should vacate his judgment and remand for a new trial based on two instances where he contended the district court improperly admitted hearsay evidence. As a preliminary matter, Roman-Lopez challenged the proper standard of review for hearsay rulings. From this, he argued the State would not be able to show that the errors were harmless beyond a reasonable doubt, and that the cumulative effect of the errors deprived him of a fair trial. Apart from alleged errors at trial, Roman-Lopez maintained that remand was necessary because the district court did not redline portions of the presentence investigation report it allegedly accepted. Roman-Lopez’s appeal was initially heard by the Court of Appeals, which affirmed. The Supreme Court affirmed Roman-Lopez’s judgment of conviction and declined to remand the matter to redline portions of the presentence investigation report. View "Idaho v. Roman-Lopez" on Justia Law

In this appeal, the issue presented was whether a contract for the sale of business assets also contained language conveying an enforceable leasehold interest in real property in favor of the buyer. At summary judgment, the district court determined that the Ellis Family Trust owned the real property underlying this leasehold dispute, and that the contract selling the assets of Pullover Prints Corporation (“PPC”) to 616, Inc. (“616”) did not convey a leasehold interest to 616 because material terms necessary to form a valid and enforceable lease were missing. Instead, the district court concluded that the contract involving the sale of assets only contained an “agreement to agree” on the terms of a written lease at a later date. Accordingly, the district court entered judgment in favor of the Ellis Family Trust. 616 appealed, arguing that all material terms necessary to form a valid and enforceable lease could be found within the asset contract. Respondents PPC, Mae Properties, LLC (“Mae”), and Ellis in his individual capacity and in his capacity as trustee for the Ellis Family Trust, cross-appealed the district court’s decision regarding their collective motion for attorney fees. Finding no reversible error in either the appeal or cross-appeal, the Idaho Supreme Court affirmed. View "616 Inc. v. Mae Properties, LLC" on Justia Law