Justia Idaho Supreme Court Opinion Summaries

Juan Jimenez filed a pro se petition for post-conviction relief and requested that counsel be appointed to represent him under Idaho Code section 19- 4904. In November 2018, Jimenez was charged with felony possession of a controlled and possession of contraband in a correctional facility. Pursuant to a plea agreement, he entered an Alford plea to the controlled substance charge and a judgment of conviction was entered in December 2018. The district court sentenced Jimenez to a three-year unified sentence with the first six months de terminate, to run consecutively to the sentences he was already serving. For his post-conviction relief petition, the district court appointed an attorney to represent Jimenez but limited the scope of his counsel’s representation to a single claim in the petition: his Rule 35 ineffective assistance of counsel claim. Jimenez argued the district court erred by limiting appointed counsel’s representation. To this, the Idaho Supreme Court agreed. Accordingly, the Supreme Court vacated the judgment dismissing Jimenez’s petition, and remanded for further proceedings. View "Jimenez v. Idaho" on Justia Law

The issue presented for the Idaho Supreme Court's review in this case arose from a March 2020 traffic stop where a single officer, without having reasonable suspicion that a crime involving the passenger was afoot, checked the passenger for outstanding warrants. The officer used her patrol vehicle’s computer and received a “hit” for a warrant and arrested the passenger. After the arrest, the officer discovered methamphetamine in the passenger’s purse, the rear of the patrol vehicle where the passenger was seated, and on the passenger’s person. The district court ordered the methamphetamine evidence suppressed after concluding the officer unlawfully extended the traffic stop by checking the passenger for outstanding warrants absent reasonable suspicion or a safety justification particular to that stop. The Supreme Court reversed and remanded the trial court's judgment, finding that the Fourth Amendment permits law enforcement to check passengers for outstanding warrants as a matter of course during traffic stops because of officer safety concerns. View "Idaho v. Wharton" on Justia Law

Daniel Sharp suffered an injury to his lower back from an accident at work in 2015. After surgery, he was repeatedly advised to lose weight by the medical providers treating his injury. However, Sharp gained considerable weight instead. The Industrial Commission found that Sharp’s functional ability had diminished between 2016, when he reached maximal medical improvement (MMI) after surgery, and 2019, when his permanent disability hearing was held. The Commission attributed the worsening of Sharp’s condition to his weight gain, which it held to be a superseding cause of any increase in Sharp’s disability post-MMI. Accordingly, the Commission evaluated Sharp’s disability based on his condition at MMI, despite the Idaho Supreme Court's opinion in Brown v. Home Depot, 272 P.3d 577 (2012), requiring that a claimant’s disability be evaluated based on circumstances at time of the hearing. After review in this case, the Supreme Court held that the Commission erred by departing from "Brown," by applying an incorrect standard to determine that Sharp was not entitled to compensation due to the aggravation of his injury, and by reaching certain factual conclusions not supported by substantial and competent evidence. Therefore, the Commission’s decision was vacated and the matter remanded for further proceedings. View "Sharp v. Thomas Bros Plumbing" on Justia Law

This appeal centered around the Idaho Department of Water Resources' (“IDWR”) denial of Application 83160, brought by Jeffrey and Chana Duffin (“Duffin”), to transfer the licensed ground water right 35-7667 to a different parcel of land. During the appeal of this case, 3G AG LLC (“the LLC”) “purchased from Duffin the property where water right 35-7667 - the water right subject to Transfer No. 8316 which is the subject of this appeal - is located.” As a result of the transfer of ownership, the LLC sought to substitute itself for Duffin. Because there was no objection to the substitution, it was allowed. IDWR denied the transfer because, among other reasons, approving it would cause an “enlargement” in the use of water as proscribed by Idaho Code section 42-222(1). On judicial review, the district court agreed with the denial and affirmed. Finding no error in the district court's judgment, the Idaho Supreme Court affirmed the decision of the district court. View "3G AG LLC v. IDWR" on Justia Law

S Bar Ranch owned approximately 3000 acres of land in rural Elmore County, Idaho. S Bar purchased the land in 2015. There were very few structures on S Bar’s property, save for an airplane hangar that included a five-hundred square-foot apartment. S Bar’s address was listed in Sun Valley, Idaho, and its principal, Chris Stephens, used the property for recreational purposes. Cat Creek Energy, LLC, an Idaho company managed by John Faulkner, owned and managed more than 23,000 acres of land in Elmore County near Anderson Ranch reservoir. Faulkner, on behalf of his other companies, leased land to Cat Creek to develop the project at issue in this dispute. In late 2014 and early 2015, Cat Creek began the process of obtaining conditional use permits (“CUPs”) for a proposed alternative energy development (“the project”) in Elmore County. As initially proposed, the project had five components: a 50,000 acre-foot reservoir with hydroelectric turbines, up to 39 wind turbines, approximately 174,000 photovoltaic solar panels, electrical transmission lines, and an onsite power substation. Cat Creek sought to build the project on approximately 23,000 acres of land that it had leased near Anderson Ranch Reservoir. In 2019, the district court issued a Memorandum Decision and Order, affirming the Board’s decisions with respect to the CUPs. The district court found that S Bar only had standing to challenge the CUPs relating to wind turbines, electric transmission lines, and the on-site substation. The district court also reiterated its prior oral ruling that a 2017 CUP Order was a final agency action and that S Bar’s petition for judicial review of that order was untimely. With regard to the development agreement and a 2018 CUP Amendment, the district court concluded that the Board did not err in a manner specified by Idaho Code section 67-5279 and that S Bar had not shown that its substantial rights had been prejudiced. S Bar appealed, but finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed judgment in favor of Cat Creek. View "S Bar Ranch v. Elmore County" on Justia Law

Cory Campbell appealed his sentence arising from his conviction of two counts of battery with attempt to commit rape. Campbell, who was seventeen at the time, was charged with five felony offenses related to multiple victims: four counts of rape and one count of forcible penetration by use of a foreign object. He was charged as an adult pursuant to Idaho Code section 20-509. Campbell ultimately pleaded guilty to amended charges: two counts of battery with attempt to commit rape, both against the same victim. The district court accepted Campbell’s pleas, and the State dismissed all remaining counts. In accordance with the plea agreement, both sides were free to argue at sentencing and nothing was binding on the court. In determining an appropriate sentence, the district court was permitted to consider not only the crimes perpetrated against the victim of the amended charges, but also the crimes alleged by the victims of the dismissed charges and of additional uncharged offenses. In all, Campbell had ten victims. The district court sentenced Campbell to a twenty-year determinate sentence on Count I and to a twenty-year indeterminate sentence on Count II, sentences to be served consecutively. Finding no reversible error, the Idaho Supreme Court affirmed Campbell's sentence. View "Idaho v. Campbell" on Justia Law

Defendant-appellant Desiree Karst appealed a district court’s partial denial of her motion to suppress evidence obtained during a traffic stop. Karst argued on appeal that the police sergeant impermissibly extended the traffic stop when he briefly interrupted his traffic-related investigation to contact dispatch and request a drug-dog unit at the scene. The Court of Appeals affirmed the district court’s decision, citing its recent decision in Idaho v. Still, 458 P.3d 220 (Ct. App. 2019). The Idaho Supreme Court granted Karst’s petition for review, overruled Still, reversed the district court’s decision, and remanded for further proceedings. The Supreme Court found that an unlawful extension of a traffic stop occurs when an officer’s detour prolongs, or adds time to, the original purpose for the stop. The Court of Appeals’ decision in Still improperly required “abandonment” of the traffic mission for a stop to become unlawfully extended. Here, the Court found the arresting sergeant indeed impermissibly extended the duration of the traffic stop when he requested the drug- dog unit, in violation of the Fourth Amendment. View "Idaho v. Karst" on Justia Law

Defendant Mark Wilson was charged with unlawful possession of a firearm in violation of Idaho Code section 18- 3316. The charge also carried with it a persistent violator sentencing enhancement. In a bifurcated trial, a jury first found Wilson guilty of unlawful possession of a firearm. The jury then found Wilson subject to an enhanced sentence due to his status as a persistent violator. Wilson appealed to the Idaho Court of Appeals, arguing that the State had failed to present sufficient evidence that he had been convicted of at least one previous felony at the time he possessed a firearm. Wilson also argued that the State failed to present sufficient evidence that he had been convicted of two prior felonies (an essential prerequisite of the persistent violator enhancement). The Court of Appeals affirmed Wilson’s convictions. Finding no reversible error, the Idaho Supreme Court affirmed Wilson’s convictions. View "Idaho v. Wilson" on Justia Law

Miguel and Janice Aizpitarte sued their neighbors Michael and Laura Minear to quiet title to what they contended was an established easement for an access driveway, and sought a declaratory judgment to recognize their right to an implied easement by prior use. The Aizpitartes also sought injunctive relief enjoining the Minears from blocking access to the drive(10) Wilkins (way. The Aizpitartes moved for summary judgment, which the district court granted. The district court concluded the Aizpitartes had an implied easement by prior use of the driveway crossing the Minear property to the Aizpitarte property. The Minears appealed, arguing the district court erred in granting summary judgment against them because there were genuine issues of material fact in the record. They also argue the scope of the easement recognized by the district court was too broad. Finding no reversible error in the trial court’s grant of summary judgment, the Idaho Supreme Court affirmed. View "Aizpitarte v. Minear" on Justia Law

Defendant-appellant Jennifer Olsen contended the application of withheld judgments in Idaho violated Idaho Code section 19-2601 because it caused criminal defendants to be convicted, thereby negating the legal benefits envisioned by the statute. Olsen was charged with misdemeanor driving under the influence, first offense. She entered into a plea agreement with the State, but later asked the magistrate court to not accept her guilty plea and grant her a “true” withheld judgment instead—i.e., one by which no conviction would take place . The magistrate court denied her motion, accepted her guilty plea, and granted her a withheld judgment. As part of the withheld judgment, the magistrate court: placed Olsen on supervised probation for 12 months subject to certain conditions, including: a requirement that she pay a fine and court costs; that her driving privileges be suspended for 180 days; that an interlock system be installed in her car; and that she attend Court Alcohol School and the Victim’s Impact Panel. Olsen appealed the magistrate court’s denial of her request for a “true” withheld judgment, and contented that court’s grant of a withheld judgment was not appropriately applied or effectuated. Finding no reversible error in the magistrate court’s judgment, the Idaho Supreme Court affirmed. View "Idaho v. Olsen" on Justia Law