Justia Idaho Supreme Court Opinion Summaries

This case arose out of a dispute over provisions in a written contract for sewer drainage and treatment services between Groveland Water and Sewer District (“GWSD”) and the City of Blackfoot (“the City”). Individuals living outside city limits, or entities located outside city limits, but within GWSD, were required to sign a “consent to annex” form in order for the City to agree to connect them to sewer services. The dispute ultimately made its way to district court, where GWSD alleged that the City’s requirement violated GWSD’s jurisdictional sovereignty under Idaho Code section 42-3212. GWSD’s complaint against the City sought: (1) a declaratory judgment; (2) a finding of anticipatory breach of contract; and (3) injunctive relief. On motions from the parties, the district court granted GWSD’s request for preliminary injunction and for partial summary judgment on the anticipatory breach claim. After further motions, the district court granted summary judgment to GWSD on the remaining claims. The City appeals. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decisions. View "Groveland Water and Sewer Dist v. City of Blackfoot" on Justia Law

Alejandra Ochoa was convicted by jury of misdemeanor vehicular manslaughter. She appealed her conviction to the district court, which vacated the judgment of conviction and remanded the case for a new trial. The district court held that the magistrate court erred in excluding certain toxicological evidence, refusing to grant defendant’s request to continue the trial, and allowing the State’s pathologist to testify. The State appealed the district court’s decision. The Idaho Supreme Court determined the district court erred in reversing the magistrate court’s decision to not admit the results of the toxicology report, and erred in reversing the magistrate court's denial of the motion for a continuance. Further, the Court found the district court erred in reversing the magistrate court’s decision to allow the forensic pathologist to testify concerning the cause of death. The case was remanded to the district court with instructions to reinstate Ochoa's judgment of conviction. View "Idaho v. Ochoa" on Justia Law

Stephan Byrd and Erika Mullins jointly filed an application for an encroachment permit with the Idaho Department of Lands to add boat lifts to their existing two-family dock on Priest Lake. Neighbors Cal Larson and Steven Coffey objected the application, arguing that Coffey owned a strip of land between the ordinary high water mark of Priest Lake and the waterward boundary lines of the Appellants’ properties. Following an administrative hearing, the Department of Lands denied the encroachment permit upon concluding that the record failed to show by a preponderance of the evidence that Byrd and Mullins were littoral property owners with corresponding littoral rights (a key requirement to build or enlarge encroachments on the lake under Idaho’s Lake Protection Act). Finding no reversible error in that finding, the Idaho Supreme Court affirmed the district court's judgment upholding the Department's order. View "Byrd v. Idaho State Brd. of Land Commissioners" on Justia Law

Michael McDermott appealed his conviction for second-degree murder. McDermott arrived at his ex-girlfriend’s home late at night in the hopes of obtaining methamphetamine. After finding another man, Robert Waholi, inside the ex-girlfriend’s recreational vehicle (“RV”), McDermott slammed his ex-girlfriend’s head twice in her front door, causing her to fall. McDermott exited the RV and then, a few moments later, Waholi came out carrying a large double-edged axe. McDermott shot Waholi through the heart, killing him. McDermott eventually confessed to the police that he had killed Waholi; however, he claimed he was acting in self-defense. The Idaho Supreme Court determined the district court erroneously instructed the jury on the concept of malice, rendering McDermott's trial unfair. The conviction was vacated, and the case remanded for a new trial. View "Idaho v. McDermott" on Justia Law

Christopher and Debra James appealed a district court order granting summary judgment in favor of the Idaho State Tax Commission (“Tax Commission”), reversing the decision of the Board of Tax Appeals (“BTA”). The district court affirmed the Tax Commission’s notice of deficiency decision, which disallowed a net operating loss carryback because the Jameses missed the deadline to claim the loss. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decision: Idaho Code sections 63-3072(e) and 63-3022(c)(2) required the Jameses to file their amended 2012 Idaho tax return by December 31, 2015, to carryback their 2014 NOL to the 2012 tax year. The Jameses failed to do so. View "Idaho State Tax Commission v. James" on Justia Law

While incarcerated in the Ada County jail, Appellant Tom Williamson fell from the upper bunk bed during a request that he stand for roll call. Williamson suffered a head injury and sued Respondents Ada County and the Ada County Sheriff (collectively “Ada County”), alleging they were negligent in maintaining unsafe bunk beds, ordering him to descend from the top bunk bed for roll call, and in responding to injuries he suffered. The district court dismissed the case after concluding Ada County was immune from liability under Idaho Code sections 6-904(1) and 904B(5). Williamson appealed. After review, the Idaho Supreme Court reversed the district court’s decision to dismiss Williamson’s claim that Ada County was negligent in ordering him to descend from the top bunk for roll call, and remanded the case for further proceedings. The Court affirmed the district court’s dismissal of Williamson’s remaining claims. View "Williamson v. Ada County" on Justia Law

This case arose from a petition asserting the Idaho Commission for Reapportionment (“the Commission”) violated Idaho Code section 72-1506 when it adopted Plan C03, the congressional reapportionment plan, following the 2020 federal census. Petitioner Christopher Pentico argued the Commission failed to timely submit its plan and final report, and that Plan C03 violated Idaho Code section 72-1506 by splitting local precinct boundary lines. Pentico requested the Idaho Supreme Court issue a writ of prohibition to restrain the Secretary of State from transmitting a copy of the Commission’s Final Report and Plan C03 to the President Pro Tempore of the Idaho Senate and the Speaker of the Idaho House of Representatives. The Supreme Court declined, finding the Commission filed its Final Report within the ninety-day deadline, and pursuant to Idaho Code section 72-1506(7), a commission need not retain local precinct boundary lines with respect to its congressional plan if it determines it cannot complete its duties for a legislative district while retaining precincts. View "Pentico v. Idaho Commission for Reapportionment" on Justia Law

Tyler Clapp appealed his conviction for driving under the influence. After stopping Clapp for “spinning cookies” in a parking lot, police became suspicious that Clapp was intoxicated. Clapp refused to submit to any field sobriety tests. Police then obtained a warrant for a blood draw, which showed that Clapp’s blood alcohol content (“BAC”) was 0.152 several hours after initially detaining him. At trial, the State sought to introduce the results of the blood draw. Over Clapp’s objection, the district court allowed the nurse who conducted the blood draw to testify telephonically to his qualifications in order to lay sufficient foundation to admit the results of the blood draw. The results of the blood draw were ultimately admitted, and the jury convicted Clapp of driving under the influence. Clapp appealed. The Idaho Supreme Court found the telephonic testimony violated Clapp’s right to confrontation, "'the face-to-face confrontation requirement is not absolute does not, of course, mean that it may be easily dispensed with. ... [A] defendant’s right to confront accusatory witnesses may be satisfied absent a physical, face-to-face confrontation at trial only where denial of such confrontation is necessary to further an important public policy and only where the reliability of the testimony is otherwise assured.' Both requirements must be met." Further, the Supreme Court determined the State failed to meet its burden establishing harmless error. The conviction was vacated and the matter remanded for further proceedings. View "Idaho v. Clapp" on Justia Law

This appeal consisted of two consolidated cases concerning drug-related charges. Casey Casper appealed his sentence, arguing it was excessive in light of mitigating factors he claimed the district court failed to properly consider. Casper also challenged certain restitution costs awarded to the State, claiming that they were unlawful under a plain interpretation of Idaho Code section 37- 2732(k). After review, the Idaho Supreme Court determined the district court did not abuse its discretion by imposing a ten-year sentence with three years fixed. The Supreme Court affirmed Casper's conviction and the resulting sentence and order of restitution. View "Idaho v. Casper" on Justia Law

Gregory Wade Towner, Sr., appealed his conviction for possession of methamphetamine. The arresting officer found the contraband on Towner’s person during a warrantless search. Towner moved to suppress, arguing that the officer’s conduct violated his constitutional rights against unreasonable search and seizure. The district court denied Towner’s motion after concluding that the officer’s seizure and subsequent search were a reasonable exercise of the officer’s community caretaking function. Towner appealed and the Idaho Court of Appeals affirmed. The Idaho Supreme Court granted Towner’s petition for review, and reversed, finding the trial court erred in concluding the officer's act of taking Towner into protective custody was within the officer’s authority under the community caretaker exception to the Fourth Amendment without considering the requirements of Idaho Code section 66-326(1). The case was remanded with instructions for the trial court to enter findings of fact related to whether the State proved that Towner was “gravely disabled” or an “imminent danger” to himself or others because of his mental illness under Idaho Code section 66-326(1), before he was taken into protective custody. View "Idaho v. Towner" on Justia Law