Justia Idaho Supreme Court Opinion Summaries

This appeal arose from a district court’s decision denying a motion for sanctions and attorney fees against Roy Gilbert’s former attorney, William Mitchell. The underlying litigation giving rise to the sanctions request stemmed from a dispute over a medical transport business and the business relationship between Gilbert and Richard Radnovich. Gilbert was the sole member of two LLCs: Resilient Transportation Leasing, LLC, and Resilient Transport LLC. According to Gilbert’s complaint, Radnovich was allegedly the owner of two business entities: Injury Care Emergency Medical Services (ICEMS) LLC and “Injury Care EMS,” as well as other entities not at issue in this appeal. In 2017, Gilbert executed an agreement purporting to sell Resilient Transport, LLC, to Injury Care EMS, LLC. According to Gilbert, Injury Care EMS, LLC, was never formed. Gilbert alleged that this “fictitious” LLC was an alter ego of Radnovich. The parties signed a supplement to the agreement which amended the business name for ICEMS, LLC to ICEMS, P.C, and clarified that Resilient Transport, LLC, would be subsumed by ICEMS, P.C. into another fictitious business called “Resilient Transport Operated by Injury Care EMS,” and that Resilient Transport, LLC would later be dissolved. Following a breakdown in both the agreement and the relationship, Gilbert sued Radnovich and the business entities. Mitchell filed the initial and amended complaint on behalf of Gilbert against Radnovich. Later in the proceedings, a second attorney substituted for Mitchell and soon after, both sides stipulated to dismiss the case with prejudice. A few weeks later, Radnovich filed a motion for sanctions and attorney fees against Mitchell. The district court denied the motion. Radnovich appealed, arguing the district court abused its discretion in denying sanctions and attorney fees against Mitchell. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed the district court’s decision. View "Gilbert v. Radnovich" on Justia Law

In 2021, Paul Greer pleaded guilty to felony domestic battery and was sentenced to a prison term of not less than two and not more than seven years. He appealed, arguing the district court abused its discretion when it: (1) failed to redline two requested corrections to the presentence investigation report ("PSI"); and (2) imposed an unreasonable sentence. The Idaho Court of Appeals rejected Greer’s argument regarding the PSI, holding that the record was insufficient to support the appeal because it included only “the PSI that was created prior to sentencing,” not the actual and potentially erroneous report distributed to the Idaho Department of Correction. The Court of Appeals also concluded that the sentence imposed was not unreasonable. The Idaho Supreme Court concluded the district court abused its discretion when it failed to update the portions of the PSI it previously agreed were inaccurate. The court did not abuse its discretion by imposing a unified term of not less than two and not more than seven years. Judgment was thus reversed in part, affirmed in part, and remanded for further proceedings. View "Idaho v. Greer" on Justia Law

Plaintiff-appellant Robert Stark appealed the dismissal of his petition for post-conviction relief. Stark alleged his trial counsel rendered ineffective assistance for failing to file a motion to suppress the contents of a backpack that was searched incident to Stark’s arrest. The district court dismissed Stark’s ineffective assistance of counsel claim, finding Stark did not show deficient performance or prejudice. The district court found that even if a motion to suppress had been filed, it would have been denied, either because Stark disclaimed ownership of the backpack before it was searched or because the contents of the backpack would have been inevitably discovered. Stark challenged the district court’s ruling by arguing that a motion to suppress would have been granted because: (1) the backpack was not lawfully searched incident to his arrest; (2) the contents of the backpack would not have been inevitably discovered; and (3) his disclaimer of ownership was legally ineffective. Stark thereafter appealed to the Court of Appeals, which affirmed the dismissal. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed it. View "Stark v. Idaho" on Justia Law

Ross Lamm and Leslie Preston each began separate businesses during their marriage. After Lamm filed for divorce from Leslie Preston, they stipulated to a custody and support order for their children, as well as the division of most of their marital estate; however, they could not reach an agreement on the valuations of their respective businesses. Following a bench trial, the magistrate court determined that the couple’s 25% interest in one of those businesses, Black Sage Acquisition, LLC, was worth $163,373 based on its fair market value. All remaining value was found to be Lamm's personal goodwill. Preston first appealed the magistrate court’s valuation and division of certain business assets in her divorce proceedings to the district court, which upheld the magistrate court’s ruling. She then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the magistrate court's order. View "Lamm v. Preston" on Justia Law

This appeal arose from a contempt order entered against Jeff Katseanes (“Jeff”) and an order of disgorgement entered against his attorney, Justin Oleson. As part of a divorce agreement between Judy Katseanes, now Judy Yancey (“Judy”), and Jeff, Jeff was required to pay Judy spousal support. Following several years of insufficient payments, Judy filed a lawsuit to seek enforcement of spousal support. During the proceedings, the district court orally granted Judy’s request for a Qualified Domestic Relations Order (“QDRO”) assigning Judy 100% of Jeff’s 401k plan. After the court orally issued its order in open court, but before the district court signed a written order reflecting the oral ruling, Jeff withdrew all of the funds from the 401k. The district court ordered Jeff to return the funds and provide an accounting. When the accounting was not timely provided, the district court held Jeff in criminal contempt and sentenced him to five days in jail. The court also granted an order of disgorgement against his attorney after discovering Jeff’s attorney fees had been paid with funds from the 401k. Jeff appealed to the Idaho Supreme Court, arguing the order of contempt and order of disgorgement were improper because the QDRO did not become effective until the written order was signed by the court. Finding no reversible error, the Supreme Court affirmed. View "Katseanes v. Katseanes" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on whether the Idaho Constitution protects abortion from the legislature's broad power to enact laws concerning the public’s health, welfare, and safety. Planned Parenthood Great Northwest, Hawaii, Alaska, Indiana, Kentucky, and Caitlin Gustafson, M.D., on behalf of herself and her patients (collectively “Petitioners”), brought three petitions, each seeking a writ of prohibition and declaratory relief blocking implementation and enforcement of recently enacted laws in Idaho. Petitioners also raised various facial challenges, claiming these laws offend important constitutional principles, such as equal protection, due process, the special laws provision, the separation of powers doctrine, and purported “informational privacy” protections under the Idaho Constitution. Petitioners further claimed that the Idaho Human Rights Act limited the legislature’s ability to regulate abortion through the Total Abortion Ban and 6-Week Ban. After careful consideration of the issued raised, the Idaho Supreme Court denied Petitioners’ requests for extraordinary writs of prohibition and declaratory relief. View "Planned Parenthood Great Northwest, et al. v. Idaho" on Justia Law

This issue this appeal raised for the Idaho Supreme Court's review centered on the proper legal standards for assessing discovery sanctions against trial counsel, and for proving the character of property during divorce proceedings. Appellant Josh Erickson argued the magistrate court erred by applying the community property presumption to three retirement accounts he owned prior to marriage. Josh argued he failed to produce documents during discovery that could have established these accounts were his separate property because the Respondent Amy Erickson, did not give timely notice that she was seeking an interest in the retirement accounts. Josh argued the magistrate court then imposed inequitable sanctions at trial for his alleged discovery violations by preventing him from presenting evidence relevant to the claims Amy was permitted to make outside the discovery window. Josh appealed the magistrate court’s decision to the district court, which affirmed. After review, the Supreme Court affirmed the district court’s determination that Josh failed to establish that the retirement accounts were his separate property. The Court reversed the district court’s denial of Amy’s request for attorney fees and remanded for consideration on the merits. View "Erickson v. Erickson" on Justia Law

Jessie Adams appealed an order to pay $15,053.49 in restitution stemming from his conviction of petit theft. The State charged Adams with two separate counts of grand theft. A jury found Adams guilty of the first charge of grand theft; as to the second charge, the jury acquitted Adams of grand theft but found him guilty of the lesser-included offense of petit theft. The district court ordered Adams to pay $15,053.49 in restitution related to his conviction for petit theft. Adams argued the district court had abused its discretion in ordering restitution in an amount greater than $999.99, “the amount associated with the statutory delineation between grand theft and petit theft.” The Idaho Supreme Court concurred the district court abused its discretion by ordering restitution in excess of $1000. The judgment was therefore vacated and the matter remanded for further proceedings. View "Idaho v. Adams" on Justia Law

In 2019, an Idaho district court granted Respondents Matthew and Bonnie Latvalas’ claim for a prescriptive easement over a road known as “South Camp Bay Road” to reach their property located on the shores of Lake Pend Oreille. Because the prescriptive easement was created by the operations of an active mine, the district court determined that the scope of the easement included the ability to transport labor and materials to build a home on the Latvalas’ property. In Latvala v. Green Enterprises, Inc., 485 P.3d 1129 (2021) (Latvala I), the Idaho Supreme Court affirmed the district court’s determination that the Latvalas had a prescriptive easement over South Camp Bay Road. However, the Court vacated the district court’s judgment after concluding it had impermissibly expanded the scope of that easement. On remand, the parties disputed whether the Supreme Court’s decision prohibited the Latvalas’ proposed residential use of South Camp Bay Road, or only the construction of a residence on the Latvalas’ property. The district court entered a second amended judgment that prohibited the Latvalas from using South Camp Bay Road to construct a residence on their property, but did not restrict the Latvalas from using the road for residential purposes. Appellants Green Enterprises, Inc., James and and Julie Frank, and Larimore and Kathryn Cummins (neighboring landowners) timely appealed. Finding no reversible error in the latter district court judgment, the Supreme Court affirmed: “Because possibly driving across South Camp Bay Road will do nothing to increase the burden on the servient landowners, we affirm the district court’s second and third amended judgments because they are consistent with our holding in Latvala I. The Latvalas may not use South Camp Bay Road to build a residence; they may drive along Camp Bay Road to access a residence. Whether and to what extent that burden may or could change in the future is a question for another day. On the record before us we will not hypothesize on what the outcome would be under those theoretical scenarios.” View "Latvala v. Green Enterprises, Inc." on Justia Law

Chad Schiermeier appealed the summary disposition of his petition for post-conviction relief. In 2017, Schiermeier was charged and convicted of one count of grand theft for stealing money from the Blaine County Sheriff’s DARE program. Schiermeier, a Blaine County Deputy Sheriff, had been the manager of the program for several years and had spent large sums of the program’s money on various items for his personal use. Schiermeier appealed his conviction and sentence to the Idaho Supreme Court, which then affirmed. In 2020, Schiermeier, through the same private attorney who had represented him during his trial, petitioned for post-conviction relief, arguing that his appellate counsel (a Deputy State Appellate Public Defender) had been ineffective for failing to raise several issues in his direct appeal. The State moved for summary disposition, which the district court granted. Schiermeier timely appealed. Finding no reversible error, the Supreme Court affirmed the district court’s summary disposition of Schiermeier’s petition for post-conviction relief. View "Schiermeier v. Idaho" on Justia Law