Justia Idaho Supreme Court Opinion Summaries

Brian Hollist challenged a district court’s denial of his motion to suppress evidence. Hollist was arrested in Idaho Falls after an officer approached him while he was sleeping on a canal bank. The officer was responding to check on Hollist's welfare. After advising the officer he did not need medical assistance, Hollist attempted to leave several times; however, each time the officer insisted that Hollist remain. When Hollist declined to identify himself, the officer handcuffed him and ordered him to sit down on the grass. The officer later discovered that Hollist had an outstanding warrant for his arrest. Following his arrest, officers found a glass pipe with white residue and a bag with a small amount of methamphetamine inside. Before trial, Hollist moved to suppress the methamphetamine and pipe, arguing: (1) the officer was not performing a community caretaking function at the time he was detained; (2) the officer did not have reasonable suspicion to detain him; and (3) the eventual discovery of the arrest warrant did not purge the taint of his unlawful seizure. The district court denied Hollist’s motion to suppress. Hollist timely appealed. The Idaho Supreme Court concluded the officer did not have a reasonable suspicion to detain Hollist, and the officer's unlawful seizure of Hollist was not sufficiently attenuated from the discovery of contraband. The district court's denial of Hollist's motion to suppress was reversed and the matter reversed for further proceedings. View "Idaho v. Hollist" on Justia Law

Black Diamond Compost, LLC (“Black Diamond”), filed a “Claim of Ownership” with the Ada County, Idaho Recorder’s Office to notify the public of its ownership of compost and humus located on real property in Ada County. Black Diamond disputed the ownership of the land and deemed it necessary to notify the public that the compost and humus located on the real property belonged to it. Ford Elsaesser, personal representative of the Estate of Victoria Smith, attempted to sell the real property but could not secure “clear title” in a preliminary title report and claimed this was due to Black Diamond’s Claim of Ownership. Elsaesser filed an action against Black Diamond, alleging the Claim of Ownership was a nonconsensual common law lien prohibited under Idaho Code section 45-811. The court agreed and ordered the release and discharge of the recorded Claim of Ownership. It also awarded Elsaesser a $5,000 civil penalty and granted his request for costs and attorney fees. The Idaho Supreme Court affirmed the district court, holding it did not err in: (1) determining the Claim of Ownership to be a prohibited nonconsensual common law lien; (2) ordering the lien to be released and discharged; (3) imposing a $5,000 civil penalty against Black Diamond; and (4) awarding attorney fees to the Personal Representative pursuant to Idaho Code section 45-811(4). View "Elsaesser v. Black Diamond Compost, LLC" on Justia Law

This appeal arose from an action in which the personal representative of the Estate of Victoria Smith (the “Personal Representative”) sought to eject Riverside Farms, LLC, (“Riverside”) from its real property, referred to by the parties as the “Chinden Property,” after the term of Riverside’s lease expired. Riverside argued that the Personal Representative lacked standing to bring the ejectment action because it was not the true owner of the land. The Personal Representative was earlier granted ownership of the “Chinden Property” pursuant to a Rule 70(b) judgment issued during the probate proceedings following Victoria’s death. Riverside argued that the Rule 70(b) judgment was barred by res judicata because a prior action, which concerned removal of trees along an easement on the property, had already confirmed that the Personal Representative was not the true owner of the Chinden Property. The district court determined that ejectment of Riverside was proper because the dismissal of the prior case did not preclude the Rule 70(b) judgment issued in the probate case. Riverside filed a motion asking the district court to reconsider its decision, but the district court declined to do so. Riverside appealed to the Idaho Supreme Court, arguing that the denial of its motion to reconsider was in error and renewing its argument that the personal representative lacked standing to seek removal of Riverside from the property because the Rule 70(b) judgment was barred by res judicata. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Elsaesser v. Riverside Farms, Inc." on Justia Law

This appeal arose from conflicting interpretations of the statutory provisions that govern the Public Employee Retirement System of Idaho (“PERSI”) and the administration of employer contributions to the Firefighters’ Retirement Fund (“FRF”). Under Idaho Code sections 59-1391 and 59-1394, a city or fire district that “employs” firefighters participating in the FRF on October 1, 1980, was considered an “employer” and required to make additional contributions to ensure the FRF remains solvent. Having employed only a single firefighter who received funds from the FRF, Kuna Rural Fire District (“KRFD”) argued it was not an employer under the code and not required to contribute to the fund because that employee retired in 1985 and received a lump-sum benefit. KRFD notified PERSI of its intent to cease contributions, but PERSI denied this request. KRFD filed a notice of appeal to the PERSI Retirement Board (“Board”). A hearing officer issued a recommended decision concluding KRFD had to continue contributing under section 59-1394. The Board adopted this decision. KRFD petitioned for judicial review under the Idaho Administrative Procedure Act (“IDAPA”) with the district court, which affirmed the Board’s decision. KRFD timely appealed to the Idaho Supreme Court. Finding no error, the Supreme Court also affirmed the Board's decision. View "Kuna Rural Fire District v. PERSI" on Justia Law

In 2017, Appellant Shoshone County assessed properties owned by Respondents S&W OPS, LLC; POWDER, LLC; H2O, LLC; GOLF, LLC; APARTMENT, LLC; F&B, LLC; and VILLAGE MANAGEMENT, LLC (collectively “Taxpayers”). Taxpayers disputed the valuation and sought review by the Board of Equalization, and subsequently the Board of Tax Appeals (“BTA”). The BTA reduced the assessed value, and the County appealed to the district court. After a four-day bench trial, the district court upheld the BTA decision, determining that the County’s appraisal evidence was more credible than Taxpayers’ evidence; however, the district court ultimately held the County had not satisfied its burden of showing how the BTA decision was erroneous by a preponderance of the evidence. The County appealed to the Idaho Supreme Court, arguing that the district court applied the wrong standard of review by requiring the County to prove “how or why” the BTA decision was erroneous instead of simply concluding that the market value of the property was different than what was found by the BTA. After review, the Supreme Court agreed with the County’s position. The district court’s decision was reversed, the judgment was vacated, and the case was remanded with instructions for the district court to consider whether the BTA’s decision on valuation was erroneous given the evidence submitted during the de novo trial. If that decision on valuation was erroneous, the district court, as the fact-finder, had to set the valuation. View "Shoshone County v. S&W OPS, LLC" on Justia Law

This case involved an investigatory detention of Jeremey Huntley based on a series of tips, corroborated in part, from a known confidential informant that Huntley was trafficking methamphetamine into Idaho. Huntley moved to suppress the methamphetamine evidence found on his person and in his vehicle found during a search after the stop. The district court granted Huntley’s motion after concluding the officers lacked reasonable suspicion for the stop and that it was unlawfully prolonged. The State appealed. The Idaho Supreme Court reversed, finding that the tips and corroboration supplied the officers with reasonable suspicion to stop Huntley, and the stop was not unlawfully extended because the detectives never deviated from the original purpose of the stop. View "Idaho v. Huntley" on Justia Law

Patricia Allen appealed the Idaho Industrial Commission’s (the “Commission”) decision denying unemployment benefits. Allen was employed by Partners in Healthcare, Inc., doing business as North Canyon Medical Center (“NCMC”), between February 5, 1999, and May 8, 2020. On May 8, 2020, the CEO of NCMC and the HR director met with Allen to discuss her job performance. Allen was presented with a performance improvement plan (“PIP”), which outlined examples of Allen’s poor job performance and identified expectations for improving her performance. It was explained to Allen that if she wanted to forego the PIP, she could sign a severance agreement. Allen was then presented with a proposed severance agreement. Allen asked if she could discuss her options with her husband, but was pressed to make her decision then and there. The CEO told Allen that he thought it was in her best interest to take the severance package. Allen decided to forgo the PIP and took the severance agreement. After separating from NCMC, Allen filed an unemployment claim with the Idaho Department of Labor (“IDOL”). NCMC’s response to the Idaho Department of Labor was prepared by the Idaho Hospital Association (“IHA”), NCMC’s third-party administrator. IHA’s human resources director identified Allen’s reason for separation as “Fired/Discharged” and indicated Allen did not receive any compensation after her separation. IDOL determined Allen was eligible for unemployment benefits. NCMC’s HR director appealed the IDOL decision; IDOL sent NCMC and Allen a hearing notice on whether Allen quit voluntarily and, if so, whether she quit for good cause or was discharged for misconduct in connection with her employment. Following the hearing, the appeals examiner issued a written decision that denied Allen unemployment benefits. The examiner also found that Allen did not follow the grievance procedures to report her issues with her supervisor prior to quitting. In reversing the Commission’s decision, the Idaho Supreme Court concluded the Commission erred in failing to analyze whether the PIP was a viable option that would have allowed Allen to continue working. The matter was remanded for further proceedings. View "Allen v. Partners in Healthcare, Inc." on Justia Law

This appeal arose from the dismissal of a stepfather’s petition for custody and support of a child filed three years after the stepfather and mother divorced. The stepfather based his petition on the underlying divorce and the Idaho Supreme Court’s decision in Stockwell v. Stockwell, 775 P.2d 611 (1989). The magistrate court ultimately dismissed the stepfather’s petition for failure to state a claim upon which relief could be granted, reasoning that the stepfather, who never adopted the child, had brought a common law custody claim under Stockwell, which was specifically prohibited in Doe v. Doe, 395 P.3d 1287 (2017). The Idaho Supreme Court agreed with the magistrate court’s decision and affirmed the judgment of dismissal. View "Glatte v. Hernandez" on Justia Law

The State appealed the district court’s order granting Sunny Riley’s motion to suppress evidence obtained when a drug dog alerted on her vehicle while she was being cited for a traffic offense. Riley’s motion was granted by the district court after it concluded that the police officer’s deviations from the traffic stop measurably and unlawfully extended the duration of Riley’s seizure under the Fourth Amendment. The Idaho Supreme Court reversed, finding that while there were two deviations from the initial course of this traffic stop, the combined deviation was insufficient to change the overall length of the stop beyond the time when the drug dog alerted on the vehicle. When this occurred, it gave rise to a reasonable suspicion of drug activity and allowed officers to continue to investigate. View "Idaho v. Riley" on Justia Law

Petitioner-appellant Melvin Savage was convicted of first-degree arson. He filed a post-conviction petition alleging his trial counsel was ineffective for failing to advise him of his right against self-incrimination during a deposition that took place in a civil lawsuit involving the arson allegation. Following an evidentiary hearing, the district court found that counsel’s failure to advise Savage of his right to remain silent constituted deficient performance; however, Savage failed to prove he was prejudiced by that deficient performance because he was already intent on resolving his criminal case by entering a guilty plea at the time of the civil deposition. Savage unsuccessfully moved for reconsideration. Appealing to the Idaho Supreme Court Savage argued the district court erred by limiting its prejudice analysis to an evaluation of whether Savage would have gone to trial instead of considering whether Savage demonstrated that the outcome of the plea process would have been different with competent advice. Finding no reversible error, the Supreme Court affirmed the district court. View "Savage v. Idaho" on Justia Law