Justia Idaho Supreme Court Opinion Summaries

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

Appellants were residents of Blaine County, Idaho (the “County”) who opposed a modified conditional use permit that the County granted to Idaho Power to install above-ground power lines. After the County denied Petitioners’ motion to reconsider as untimely, Petitioners sought judicial review of the permit in district court. Intervenor, Idaho Power Company, filed a motion to dismiss the petition, which the County joined, arguing that Petitioners’ underlying motion to reconsider was untimely, thereby precluding the district court from exercising its jurisdiction over the petition. The district court granted the motion to dismiss and concluded that it lacked jurisdiction to consider the petition because the Local Land Use and Planning Act (LLUPA) required aggrieved parties to file a timely motion to reconsider prior to seeking judicial review. The district court further held that no exception to the exhaustion of administrative remedies doctrine applied. Petitioners timely appealed to the Idaho Supreme Court to resolve the question of whether the LLUPA required a timely motion to reconsider to be filed in advance of a petition for judicial review. The Supreme Court concluded the act does require the filing of a timely motion to reconsider in advance of a petition for judicial review, and, therefore, affirmed the district court's order. View "Richardson v. Blaine County" on Justia Law

Stephanie Owens appealed a district court’s order affirming the findings of fact and conclusions of law made by the Ada County Board of Commissioners (the “Board”) in which it determined that Owens was an “applicant” under the Medical Indigency Act (the “Act”) and, therefore, required to pay reimbursement for the medical expenses incurred by her two children at public expense. In 2017, Owens’s children were involved in a serious car accident and suffered substantial injuries, which later resulted in the death of one of the children. Because the children’s father, Corey Jacobs, was unable to pay for the children’s medical bills, he filed two applications for medical indigency with the Board. Owens and Jacobs were never married and did not have a formal custody agreement for their children. At the time of the accident, the children resided with their father. The Board determined that Owens and her children met the statutory requirements for medical indigency. Although Jacobs filed the applications for medical indigency, the Board concluded that Owens was also an “applicant” under the Act and liable to repay the Board. As a result, the Board “recorded notices of statutory liens” against Owens’s real and personal property and ordered Owens to sign a promissory note with Ada County to repay the medical bills. Owens refused to sign the note and instead challenged the sufficiency of her involvement with the applications via a petition for reconsideration with the Board and a subsequent petition for judicial review. Both the Board and the district court ultimately concluded that Owens was an “applicant” and liable for repayment of a portion of the children’s medical bills. Owens timely appealed. The Idaho Supreme Court reversed: because she never signed the medical indigency applications for her children and she did not affirmatively participate in the application process, Owens was not an "applicant" as defined by the Act. As a result, the Board acted outside its authority when it ordered Owens to reimburse Ada County for its expenses and when it placed automatic liens on her property. View "Owens v. Ada County Board of Commissioners" on Justia Law

Following a jury trial, Travis Leavitt was convicted for statutory rape of a 17-year-old girl. He was 34 years old at the time of the incident. After the trial had begun, the State disclosed new evidence regarding Leavitt’s past criminal record, which the district court admitted. Leavitt challenged his conviction on the basis that the court allowed impermissible propensity evidence to be presented to the jury, including evidence of his criminal sexual history. Additionally, Leavitt asserted that even if the admission of such evidence were proper under Rule 404(b), the State failed to show good cause for its late disclosure of the evidence disclosed after trial began and evidence that he was a felon and a sex offender should have been barred as unfairly prejudicial under Rule 403. Leavitt’s appeal was initially heard by the Idaho Court of Appeals, which vacated his conviction and remanded the case for a new trial in an unpublished decision. The Idaho Supreme Court granted the State’s petition for review of the Court of Appeals’ decision. Though its reasoning differed, the Court reached the same result, concurring the trial court erred, and affirming the appeals court's outcome. View "Idaho v. Leavitt" on Justia Law

In April 2018, a teller working at CapEd Credit Union called the Boise Police Department to report a suspicious situation: a man came into the credit union, made a large cash deposit, exited the building, and then changed clothes in the parking lot. The man subsequently spoke with two other men in the parking lot. The teller reported that the men’s behavior made credit union employees nervous. Officers from the Boise Police Department responded to the credit union's call and detained one man in the parking lot. As the man in the parking lot was being detained, Officer Will Reimers arrived at the scene and proceeded into the credit union without speaking to the officers in the parking lot. As he waited for an employee to unlock the doors, Reimers observed two men, Patrick Maahs and Jordon Korona, standing at the teller counter. Reimers was dressed in full police uniform. One man left the counter and proceeded down a nearby hallway, then the other man followed. An employee informed Reimers that both men had gone into a bathroom, even though they were informed that it was a single person bathroom. Reimers took a position just behind a wall at the head of the hallway leading to the bathroom and called for backup. Once Maahs left the bathroom, he was subdued by police and eventually arrested on firearms and methamphetamine possession charges. Maahs moved to suppress the evidence seized from the search of his car on the basis that officers had conducted a de facto arrest and that his seizure was unsupported by probable cause or reasonable suspicion. The Idaho Supreme Court found the district court erred in denying the motion to suppress: Maahs was arrested without probable cause, and items found in his care should have been suppressed as "fruit of the poisonous tree." Maahs' judgment of conviction was vacated and the case remanded for further proceedings. View "Idaho v. Maahs" on Justia Law