Justia Idaho Supreme Court Opinion Summaries

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

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