Justia Idaho Supreme Court Opinion Summaries

In August 2020, police interviewed Dr. Daniel Lee Moore (“Moore”) concerning the murder of Dr. Brian Drake (“Drake”), who had been shot in his chiropractic office over five months earlier. Though Moore invoked his right to an attorney at least three times, the interrogation continued. Moore eventually confessed to the crime and was charged with second-degree murder. Following a defense motion, the district court suppressed the confession after finding that Moore’s Miranda rights had been violated. The district court later dismissed the case, concluding that because the State had relied on the tainted confession in the preliminary hearing, there was insufficient evidence to support a showing of probable cause. The State appealed the dismissal, conceding that there was a Miranda violation, but arguing the district court erred in dismissing the case. Although the Miranda violation rendered Moore’s statements inadmissible in the State’s case-in-chief, the State maintains that the statements could still be used to impeach a claim of innocence by Moore if he were to testify at trial. After review, the Idaho Supreme Court affirmed in part and reversed in part. The Court affirmed the ruling that the confession was inadmissible in the State's case-in-chief, but reversed the ruling that the confession would also be admissible for impeachment purposes, should Moore testify at a future preliminary hearing or at trial. The Supreme Court affirmed the district court’s decision granting the motion to dismiss pursuant to Idaho Code section 19-815A. The rulings in this opinion as to the limited admissibility of Moore’s confession would govern any future prosecution of Moore related to the murder of Drake. View "Idaho v. Moore" on Justia Law

After receiving reminder notices by mail, the insureds failed to pay a renewal premium for a rented home by the due date. Fourteen days after payment was due, the insureds mailed a check to the insurance company for the late renewal premium. Six days later, but before the insurance company reviewed the late payment, a fire occurred at the home. Two days after the fire, the insurance company returned the late payment, denied coverage for the loss, and denied reinstatement of the policy. The insurance company subsequently brought a declaratory judgment action against the insureds. The district court granted summary judgment in favor of the insurance company. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "United Heritage v. Zech" on Justia Law

Jana Mortensen sought treatment from Dr. Jeffrey Baker at The Healing Sanctuary, LLC, after a hysterectomy failed to resolve symptoms for ongoing pelvic pain. Mortensen alleged Dr. Baker prescribed Mortensen a 14-day course of “ozone treatment” to be self-administered intravaginally at home. Mortensen allegedly breathed in ozone gas while administering the treatment, which she alleged caused her permanent pulmonary and cardiac injuries. Mortensen filed a complaint against Dr. Baker and The Healing Sanctuary (collectively “Dr. Baker”), claiming medical malpractice. Dr. Baker moved for summary judgment, arguing that Mortensen could not prove causation. The district court conditionally granted Dr. Baker’s motion for summary judgment after finding Mortensen had not raised a genuine issue of material fact; however, the court gave Mortensen a specified time to secure expert testimony on causation. Mortensen did not comply with the deadline. The district court entered summary judgment, denying Mortensen’s second request for additional time. The district court also denied her motion to reconsider. Mortensen appealed. The Idaho Supreme Court reversed, finding the district court erred in excluding certain statements. As a result, Dr. Baker was not entitled to summary judgment because the excluded testimony created a genuine issue of material fact. View "Mortensen v. Baker" on Justia Law

After a jury found Jesus Garcia guilty on charges related to a deadly night-club incident, the district court ordered restitution against Garcia in the amount of $162,285.27. In Idaho v. Garcia, 462 P.3d 1125 (2020) (“Garcia I”), the Idaho Supreme Court reversed the district court’s restitution order after determining the district court had not properly considered Garcia’s future ability to repay that amount. On remand, the district court held a second restitution hearing, weighed evidence from before and after remand, and determined Garcia had the foreseeable ability to pay the restitution amount. The district court then reinstated the original order in full. Garcia appealed, arguing the district court’s decision ignored the Supreme Court’s restitution holding in Garcia I, and was not supported by substantial evidence. Finding no reversible error, the Supreme Court affirmed the trial court. View "Idaho v. Garcia" on Justia Law

The Idaho Board of Pharmacy (“Board”) filed an administrative complaint against pharmacist Cindy Chambers, alleging that she dispensed a controlled substance without a valid prescription. Chambers prevailed before the Board and it determined that she was entitled to recover her reasonable attorney fees and costs; however, she failed to comply with the 14-day deadline for requesting her award. When she filed a request almost seven months after the deadline had passed, the Board denied her request upon finding that she failed to show good cause for the late filing. Chambers then sought judicial review from the district court, which dismissed her petition. Chambers then appealed to the Idaho Supreme Court, maintaining that both the Board and the district court erred by applying the wrong legal standard. Finding no reversible error, the Idaho Supreme Court affirmed. View "Chambers v. Idaho Board of Pharmacy" on Justia Law

Gerald Pizzuto, Jr., was convicted of two brutal murders and sentenced to death in 1986. After the Idaho Commission of Pardons and Parole voted 4-3 to recommend that Pizzuto’s death sentence be commuted to life without the possibility of parole, Idaho Governor Brad Little rejected the recommendation, thereby allowing Pizzuto’s death sentence to remain in effect. Pizzuto challenged the Governor’s action by filing an Idaho Criminal Rule 35(a) motion to correct his sentence, and a sixth petition for post-conviction relief. The district court granted both Pizzuto’s motion and petition after finding Idaho Code section 20-1016 was unconstitutional. The State appealed to the Idaho Supreme Court. Finding Idaho Code section 20-1016 was a constitutional expression of the authority granted to the Legislature, the Supreme Court determined the district court erred in granting both Pizzuto’s Rule 35(a) motion and his petition for post-conviction relief. “Both decisions were based on the erroneous grounds that Governor Little lacked authority to reject the Commission’s clemency recommendation because Idaho Code section 20-1016 is unconstitutional. … Because the 1986 amendment to Article IV, section 7, authorizes the legislature to govern the Commission’s commutation powers ‘by statute,’ and Idaho Code section 20-1016 is a proper expression of that authority, we reverse the district court’s orders and remand Pizzuto’s cases for further proceedings.” View "Idaho v. Pizzuto" on Justia Law

Defendant-appellant Ricky Weaver appealed his conviction for solicitation of murder. The State contended Weaver offered to pay a fellow inmate to murder his girlfriend while they were both being held in the Elmore County Detention Center. Weaver was subsequently charged and convicted by a jury. During his trial, Weaver attempted to elicit testimony from another prisoner, Michael Dean, that Wallace had told Dean that he made up the murder-for-hire story against Weaver in an attempt to try to get a “deal” from the prosecutor in his own case. The district court excluded the evidence on the grounds that Dean’s testimony was hearsay and inherently unreliable based on Dean’s own statements. On appeal, Weaver asserts the district court erred by excluding Dean’s testimony because the anticipated testimony: (1) was relevant because it tended to make it more probable that Wallace had not testified truthfully but instead had tried to set Weaver up in order to secure a “deal” from the prosecutor; (2) fit within the “state of mind” exception to the hearsay rule; (3) was proper impeachment of Wallace’s credibility; and (4) had probative value not outweighed by the possibility of unfair prejudice. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Weaver" on Justia Law

Gerald Neeser, in his capacity as trustee of the Gerald E. Neeser Revocable Living Trust (Neeser), owned two adjacent parcels of land, Lots 3 and 4, on the south shore of Spirit Lake in Kootenai County, Idaho. Inland Empire Paper Company (IEP) owned several hundred acres of land adjacent to Neeser’s, which it used to grow and harvest timber. Neeser filed a complaint alleging that he had a prescriptive easement over IEP’s land, specifically a road known as the “M1 Road,” for ingress and egress to his property. Both parties moved for summary judgment. The district court granted Neeser’s motion for summary judgment after concluding that Neeser had established a prescriptive easement over IEP’s land benefiting Lots 3 and 4 and that there were no genuine issues of material fact regarding that issue. Several months later, IEP moved the district court to reconsider its order on summary judgment, which the district court denied. IEP timely appealed. Finding that the district court abused its discretion in declining to strike portions of Neeser’s declaration that was outside of his personal knowledge, and that Neeser did not offer admissible evidence eliminating issues of material fact regarding the elements of a prescriptive easement, the Idaho Supreme Court reversed the grant of summary judgment. View "Neeser v. Inland Empire Paper Company" on Justia Law

Andrew Ashmore, agent for appellant Breckenridge Property Fund 2016, LLC, (“Breckenridge”) arrived at a foreclosure sale with endorsed checks to support Breckenridge’s bid. Jesse Thomas, agent for Cornerstone Properties, LLC, (“Cornerstone”) was also present. Before the auction, the auctioneer provided Ashmore and Thomas a packet of paperwork. The last page contained a requirement that endorsed checks would not be accepted as payment for a bid. Because Ashmore only had endorsed checks, the auctioneer gave Ashmore one hour to cure the payment defect, but the auction eventually proceeded with Ashmore unable to secure a different form of payment. The property ultimately sold to Cornerstone. Breckenridge filed a complaint against the two respondents and a third defendant, alleging: (1) violations of Idaho Code section 45-1506; (2) estoppel; and (3) negligence/negligence per se, seeking mainly to void the sale to Cornerstone. Breckenridge also recorded a lis pendens against the property. The district court ultimately entered summary judgment for all defendants and quashed the lis pendens. The Idaho Supreme Court found the district court abused its discretion in awarding attorney fees to Cornerstone and the auctioneer under Idaho Code section 12-120(3). The judgment was affirmed in all other respects. View "Breckenridge Property Fund 2016, LLC v. Wally Enterprises, Inc., et al." on Justia Law

Canyon County employed William Hartman as a heavy equipment operator at the Pickles Butte landfill in Nampa, Idaho, from 2012 until 2017. In February 2017, Hartman reported to Canyon County’s Human Resources Office that a female co-worker was being sexually harassed. The next month, Hartman, who was an army veteran, told both the director of the landfill, David Loper, and his immediate supervisor that he was taking narcotics prescribed to him for chronic pain. Canyon County requested Hartman provide, by a set deadline, medical documentation confirming his prescription and verifying that his use of narcotics would not adversely impact his ability to safely operate equipment. Hartman stated he was attempting to obtain the documentation, but he failed to provide it within the requested timeframe. On April 28, 2017, Loper sent Hartman a “Notice of Intent to Terminate,” informing him that his employment with Canyon County would be terminated effective May 2, 2017. The notice stated that pursuant to Rule 11.04 of the Canyon County Personnel Manual and “I.C. § 72-1701 et. seq. [sic],” Hartman could request a good faith hearing concerning the termination within two days of receiving the letter. Prior to Hartman’s receipt of the notice, Canyon County paid Hartman the balance of his accrued leave. Hartman did not request a good faith hearing. Hartman filed a notice of tort claim with Canyon County on July 27, 2017, alleging he had been unlawfully terminated. He filed a charge of discrimination with the Idaho Human Rights Commission on August 3, 2017. On November 28, 2018, Hartman filed a complaint against Canyon County, alleging: (1) disability-based discrimination in violation of the Idaho Human Rights Act (“IHRA”) and Americans with Disabilities Act (“ADA”); (2) unlawful retaliation in violation of Title VII of the Civil Rights Act (“Title VII”); and (3) unlawful termination in violation of the Uniformed Services Employment and Reemployment Rights Act (“USERRA”). Hartman later voluntarily dismissed his USERRA claim. After considering the parties’ supplemental briefing the district court issued a written decision, granting Canyon County’s motion for summary judgment. Finding that the district court erred in its grant of summary judgment, the Idaho Supreme Court reversed and remanded for further proceedings. View "Hartman v. Canyon County" on Justia Law