Justia Idaho Supreme Court Opinion Summaries

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In the case before the Supreme Court of Idaho, Michael W. Skehan appealed a decision affirming the Idaho Central Sex Offender Registry's ruling that he must register as a sex offender in Idaho. Skehan had been convicted of sexual abuse in the third degree in Oregon in 2001 and later moved to Idaho. He argued that the procedures used by the Registry were improper and that he should not be required to register.The court affirmed the lower court's decision, holding that Skehan failed to demonstrate that the Registry's ruling was deficient under Idaho Code section 67-5279(3). The court also found that Skehan failed to preserve several arguments for appeal, offered little rebuttal to the Registry's position, and did not provide a sufficient record to substantiate his claims on appeal.The court also held that Skehan failed to demonstrate that the Registry's consideration of other information in addition to the Oregon and Idaho statutes was arbitrary and capricious. Additionally, the court found that the Registry did not abuse its discretion by not considering whether his Oregon conviction was a misdemeanor or felony. Lastly, the court concluded that the Registry was not required to compare Skehan’s Oregon conviction to Idaho offenses that do not require registration.The Registry was awarded its reasonable attorney fees pursuant to Idaho Code section 12-117. View "Skehan v. ISP" on Justia Law

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Amy Shumway was employed as a receptionist at Evans Chiropractic in Idaho. Her employment was terminated by Dr. John Hitchcock, one of the owners, for insubordination. Following her termination, Shumway applied for unemployment benefits. Her application was initially approved by an Appeals Examiner from the Idaho Department of Labor (IDOL) who found Shumway eligible for benefits despite her termination for insubordination. On appeal by Evans Chiropractic, the Industrial Commission affirmed the decision, but on different grounds. Evans Chiropractic then appealed to the Supreme Court of the State of Idaho.In the Supreme Court, Evans Chiropractic argued that Shumway should not be eligible for benefits because her employment was terminated for job-related misconduct, namely her refusal to meet with Dr. Hitchcock for discussions about her behavior at work. The Supreme Court agreed, finding that the Commission erred in its application of the law. The Court noted that the Commission had focused on Shumway's subjective reasons for not meeting with Hitchcock, rather than the employer's expectations. The Court found that Hitchcock directly communicated his expectation for Shumway to meet with him and that her refusal to do so constituted insubordination, which is a form of job-related misconduct. Therefore, the Supreme Court reversed the Commission’s decision and held that Shumway was ineligible for unemployment benefits as a matter of law. View "Shumway v. IDOL" on Justia Law

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In the State of Idaho, Yellowstone Log Homes, LLC ("Yellowstone") owned a rental property in the City of Rigby that was extensively damaged after BorTek Utilities and Construction, LLC bored through a lateral sewer line connected to the rental property. The City of Rigby had failed to mark the service lateral sewer pipe connected to the rental property prior to the excavation. Yellowstone sued the City of Rigby for both negligence per se and common law negligence for failing to mark the service lateral. The district court granted summary judgment in favor of the City of Rigby, determining that Yellowstone did not have standing under the Idaho Underground Facilities Damage Prevention Act, and even if it did, it failed to prove the City breached any duty owed to it.The Supreme Court of Idaho reversed the district court's grant of summary judgment to the City of Rigby. The court found that while the Act does not explicitly provide a private right of action for "end users" like Yellowstone, it does impose a duty on the City to mark underground sewer lines in a public right-of-way, which it did not do. The court also held that whether the City breached this duty by failing to maintain records of the location of service laterals, failing to adequately mark service laterals, or failing to take other precautions to protect customers’ service laterals within the public right of way are questions of fact for a jury to decide. Thus, the court concluded that the City of Rigby owed Yellowstone a duty to act as a reasonable manager of its property under the circumstances. View "Yellowstone Log Homes, LLC v. City of Rigby" on Justia Law

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In this case, Tyler Reece Rambo was convicted on three counts of aggravated assault upon a peace officer following an incident with police at a city park in Idaho. Rambo appealed his conviction, challenging several of the district court’s evidentiary rulings concerning the admission of evidence at his trial. Rambo argued that the court erred in excluding evidence of a civil lawsuit against the Coeur d’Alene Police Department, admitting body camera footage of his gun discharging, excluding body camera footage of officers returning fire, prohibiting him from testifying about the trajectory of a bullet, and prohibiting him from showing the jury his bullet scars. The Supreme Court of the State of Idaho affirmed the majority of the district court’s rulings and determined that the district court's one erroneous relevancy determination regarding the exclusion of body cam footage indicating that Rambo’s gun did not discharge a second time, was harmless. Therefore, the Supreme Court affirmed Rambo’s judgment of conviction. View "State v. Rambo" on Justia Law

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In this case, defendant Douglas Shane Thompson was convicted for domestic violence, and a no-contact order was put in place prohibiting him from contacting his minor son. Thompson appealed against the decision, arguing that there was no evidence that he posed a threat to his son and that the no-contact order violated his fundamental right to parent his son.The Supreme Court of the State of Idaho found that the lower court failed to provide adequate reasons for amending the no-contact order to prohibit all contact between Thompson and his son. The court concluded that the lower court did not exercise reason since it did not articulate any evidence that demonstrated a change in circumstances that justified the amendment of the no-contact order. It was also noted that the court did not explain what circumstances would need to change before Thompson could seek to reinitiate contact with his son.The court also observed that Thompson's argument that the no-contact order effectively terminated his parental rights was not sufficiently preserved for appeal. The court acknowledged the complexities when a judge not regularly dealing with family law issues has to analyze often competing interests involved.Therefore, the court reversed the decision of the lower court to amend the no-contact order and remanded the case back to the district court for further proceedings. View "State v. Thompson" on Justia Law

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In this case, the Supreme Court of the State of Idaho upheld a lower court's summary judgment in favor of the defendants, George and Jesse’s Les Schwab Tire Store, Inc., and two of its owners, Bruce and Richard Byram. The plaintiff, Adam Davis, had been employed as an assistant manager at Les Schwab from April 2016 till June 2019. In March 2019, there was a shortage in the cash deposits and surveillance footage showed Davis bending down out of camera view in the area where the cash deposits were kept while he was alone in the store. This led to Davis being arrested and charged with grand theft, and his employment was terminated. Although the charges against Davis were later dropped, he sued the defendants for breach of his employment contract, false arrest, defamation per se, and for knowingly giving a false report to the police. The district court granted the defendants’ motion for summary judgment on all of Davis’s claims. The Supreme Court affirmed the lower court's decision, finding no genuine issue of material fact that could support Davis’s claims. The court found that Davis was an at-will employee who could be terminated without cause and that there was no evidence to show that the defendants had acted with malice. The court also found that the plaintiff's attorney had violated Rule 11.2 by submitting arguments that were not well grounded in fact, and awarded a portion of the defendants' attorney fees to be paid by the plaintiff's counsel. View "Davis v. George and Jesse's Les Schwab Tire Store, Inc." on Justia Law

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In a wrongful death action brought by Laura Milus on behalf of herself and her minor child against Sun Valley Company, the Supreme Court of the State of Idaho reversed the district court's grant of summary judgment to the defendant, Sun Valley. Ms. Milus' husband died after colliding with snowmaking equipment while skiing at Sun Valley Ski Resort. Ms. Milus alleged that Sun Valley breached its duties under Idaho Code section 6-1103(2) and (6), which require ski area operators to mark snowmaking equipment with visible signs or warning implements and place a conspicuous notice at or near the top of a trail or slope when snowmaking operations are being undertaken. The district court granted Sun Valley's summary judgment motion, concluding that Sun Valley had fulfilled its duty under section 6-1103(2) by marking the snowmaking equipment with yellow padding and did not have a duty under section 6-1103(6) because the snowmaking equipment was not actively discharging snow. However, the Supreme Court of the State of Idaho reversed the district court's decision, finding that the question of whether the yellow padding constitutes a warning implement under section 6-1103(2) is a question of fact for the jury. The court also held that section 6-1103(6) imposes a duty on ski area operators to place a conspicuous notice at or near the top of the trail or slope when snowmaking equipment is placed on the ski run or slope, regardless of whether the equipment is actively discharging snow. The case was remanded for further proceedings consistent with the court's opinion. View "Milus v. Sun Valley Company" on Justia Law

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The Supreme Court of Idaho affirmed the lower court's decision that A.C. & C.E. Investments, Inc. (AC&CE) did not properly plead a derivative action and lacked standing to bring a direct claim in a lawsuit against Eagle Creek Irrigation Company (Eagle Creek). AC&CE, a shareholder of Eagle Creek, a nonprofit mutual irrigation corporation, challenged amendments made to Eagle Creek's bylaws and articles of incorporation that increased the number of capital shares the corporation was authorized to issue and removed a provision that Eagle Creek would hold all the water rights it acquired “in trust” for the benefit of its shareholders. AC&CE claimed Eagle Creek breached its fiduciary duty and requested that the district court declare the proposed amendments void. However, the district court concluded that AC&CE's complaint did not properly plead a derivative action, that AC&CE lacked standing to bring a direct claim, and that the amendments were validly adopted by a majority shareholder vote. The Supreme Court of Idaho affirmed these conclusions. The court also found that AC&CE's claim regarding the increase in the number of authorized capital shares was not ripe for adjudication because no additional shares had been issued. Finally, the court affirmed the lower court's denial of Eagle Creek's request for attorney fees. View "A.C. & C.E. Investments, Inc. v. Eagle Creek Irrigation Company" on Justia Law

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In this case, the Supreme Court of the State of Idaho was required to interpret aspects of Idaho’s mechanic’s lien statutes. Datum Construction, LLC, was the general contractor for a commercial construction project, and subcontracted part of the work to Elmore Welding and Steel, who rented equipment from RE Investment Co., LLC, dba Pro Rentals & Sales. Elmore Welding and Steel failed to pay Pro Rentals for the equipment rental, resulting in Pro Rentals filing a mechanic's lien. Datum then purchased a bond and petitioned the district court to release the lien. Pro Rentals did not oppose this petition and the district court released the lien. Datum argued that Pro Rentals had failed to begin proceedings to enforce its claim of lien within six months. The district court granted Datum’s motion to release the bond. Pro Rentals appealed this decision.The Supreme Court of the State of Idaho ruled in favor of Pro Rentals, determining that the district court had erred in applying a six-month statute of limitations from the mechanic’s lien statutes to a bond action. The court held that the bond replaced the lien, and the six-month period to enforce a lien was not applicable once the lien was released. The court determined that the appropriate statute of limitations for an action against the bond was two years under Idaho Code section 5-219. Therefore, the court reversed the district court’s decision to release the bond. View "Datum Construction, LLC v. Re Investment Co." on Justia Law

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The Idaho Supreme Court ruled in favor of the Idaho State Appellate Public Defender (SAPD) in a case involving the SAPD's statutory duty to arrange for substitute counsel for indigent defendants when a conflict of interest arises. The SAPD filed a direct action against the Fourth Judicial District Court, alleging that the court infringed on the SAPD’s statutory duty to arrange a new attorney for a defendant named Azad Abdullah. The SAPD had identified a conflict of interest in its own office and tried to substitute an attorney from Pennsylvania, but the district court refused the substitution and appointed a new attorney of its own choosing. The Idaho Supreme Court held that the district court had obstructed the SAPD's statutory duty and authority under Idaho Code section 19-5906. The Court ordered the district court's decisions to be vacated, restored the SAPD as attorney of record for the limited purpose of arranging for substitute counsel, and ordered the appointment of a new district judge to preside over Abdullah’s post-conviction proceeding. View "SAPD v. Fourth Judicial District" on Justia Law