Justia Idaho Supreme Court Opinion Summaries

Daniel Genho and Riverdale Hot Springs, LLC had a dispute over payment for construction work Genho performed at Riverdale Resort. Genho was not a registered contractor at the start of the project but became registered midway through. Riverdale refused to pay Genho and prevented him from retrieving his tools and materials. Genho filed a Mechanic’s and Materialmen’s Lien and sued for breach of contract, unjust enrichment, quantum meruit, conversion, and to foreclose on the lien.The District Court of the Sixth Judicial District of Idaho granted Riverdale’s motion for a directed verdict on the breach of contract claim but denied it on the other claims. The court found that there were two separate transactions: one before and one after Genho became a registered contractor. The court allowed the jury to consider the unjust enrichment, quantum meruit, conversion, and lien foreclosure claims. The jury found in favor of Genho, awarding him $295,568, which was later reduced to $68,681. The district court also awarded attorney fees to Genho.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision in part and reversed it in part. The court held that equitable remedies are available under the Idaho Contractor Registration Act (ICRA) for work performed after a contractor becomes registered, provided the work is severable from the unregistered work. The court affirmed the denial of a directed verdict on the unjust enrichment, quantum meruit, and lien foreclosure claims but reversed the award of attorney fees for the conversion claim, as it was not based on a commercial transaction. The court also affirmed the award of attorney fees for the foreclosure action under Idaho Code section 45-513. Neither party was awarded attorney fees on appeal. The judgment was vacated and remanded for modification consistent with the opinion. View "Genho v. Riverdale Hot Springs, LLC" on Justia Law

The defendant, Jameel Fakhri Al Muthafar, was convicted of aggravated assault and attempted strangulation. The case arose when K.S., the victim, called the police from a Rite Aid store in Boise, Idaho, expressing suicidal thoughts and claiming she had been attacked by her romantic partner, Al Muthafar. K.S. was taken to St. Alphonsus Hospital, where she was diagnosed with injuries from an alleged assault. She was then referred to FACES for a forensic examination, during which she described the assault and identified Al Muthafar as the perpetrator.At the preliminary hearing, the magistrate court admitted hearsay statements made by K.S. to a nurse during the FACES examination, over Al Muthafar’s objection. The magistrate court found probable cause to bind the case over to the district court. Al Muthafar filed a motion to dismiss the Information, arguing that the hearsay statements were inadmissible and that without them, there was insufficient probable cause. The district court denied the motion, and the case proceeded to trial, where Al Muthafar was found guilty by a jury.The Supreme Court of Idaho reviewed the case and determined that the magistrate court erred in admitting the hearsay statements at the preliminary hearing, as the State failed to establish that the statements were made for the purpose of medical diagnosis or treatment. However, the court held that this error was harmless because Al Muthafar received a fair trial, where the jury found him guilty beyond a reasonable doubt based on properly admitted evidence.Additionally, the court reviewed Al Muthafar’s sentence of fifteen years with five years fixed and found no abuse of discretion by the district court. The sentence was deemed reasonable given the severity of the charges, the defendant’s risk of future violence, and his lack of remorse. The Supreme Court of Idaho affirmed both the conviction and the sentence. View "State v. Al Muthafar" on Justia Law

Michael Boren applied for a conditional use permit (CUP) to have an unimproved airstrip on his property recognized as a designated county airstrip. Gary Gadwa, Sarah Michael, and other concerned citizens opposed Boren’s application, but it was ultimately approved. Following the approval, Boren sued Gadwa, Michael, and others for defamation, defamation per se, conspiracy to commit defamation, and declaratory relief, alleging they made false statements about the airstrip and his use of it. Boren filed an amended complaint, and Gadwa and Michael moved to dismiss the claims, arguing their statements were protected by litigation privilege and constitutionally protected petitioning activity.The District Court of the Seventh Judicial District of Idaho dismissed Boren’s claims, agreeing with Gadwa’s and Michael’s arguments. The court also denied Boren’s motion to file a second amended complaint, concluding it would be futile. Boren appealed the district court’s decisions.The Supreme Court of Idaho reviewed the case and affirmed the district court’s dismissal of Boren’s civil conspiracy claim and declaratory judgment claim. However, it reversed the dismissal of most of Boren’s defamation claims, finding that the applicability of the absolute and qualified litigation privileges was not evident on the face of the complaint. The court also held that neither the First Amendment nor the Idaho Constitution provides absolute protection for defamatory statements made in the course of protected petitioning activity. The court reversed the district court’s decision denying Boren’s motion to amend his complaint, as the amendment would not be futile. The case was remanded for further proceedings consistent with the opinion. The court declined to disqualify the district judge on remand and did not award attorney fees to any party. View "Boren v. Gadwa" on Justia Law

The Idaho State Board of Education approved a proposal for the University of Idaho to purchase the University of Phoenix for $550 million, funded by a $685 million bond. This decision followed three closed-door executive sessions. Idaho Attorney General Raúl R. Labrador filed a suit to void the sale, alleging violations of the Idaho Open Meetings Law, which mandates that public policy formation be conducted openly. The district court dismissed the suit, finding no violations.The district court ruled that the Board's actions during the executive sessions were lawful under the exception in Idaho Code section 74-206(1)(e), which allows closed meetings for preliminary negotiations involving trade or commerce when in competition with other states. The court interpreted "preliminary negotiations" to include all negotiations before contracting and applied a "reasonable belief" standard to determine if the Board believed it was in competition with another governing body.The Idaho Supreme Court reviewed the case and found that the district court erred in its broad interpretation of "preliminary negotiations" and the application of the "reasonable belief" standard. The Supreme Court held that "preliminary negotiations" should be narrowly construed to mean a phase of negotiations before final negotiations, and the statute requires actual competition, not just a reasonable belief of competition. The court vacated the district court's summary judgment, its judgment following the bench trial, and the award of attorney fees and costs to the Board. The case was remanded for further proceedings consistent with the Supreme Court's interpretation of Idaho Code section 74-206(1)(e). View "Labrador v. Board of Education" on Justia Law

The State of Idaho charged Lea Anne Eaton with felony burglary and petit theft after she used discarded Walmart receipts to return stolen items for a refund. Shortly after her arrest, a new statute creating the misdemeanor offense of commercial burglary became effective. Eaton sought to reduce her felony charge to a misdemeanor under the new statute, but the district court denied her motion. Eaton entered a conditional guilty plea to felony burglary, reserving her right to appeal the denied motion. The district court sentenced her to a unified ten-year sentence with four years fixed. Eaton's subsequent motions to reconsider the denial and to correct an illegal sentence were also denied.The Idaho Court of Appeals upheld Eaton’s conviction and sentence. Eaton then petitioned for review by the Idaho Supreme Court, which granted the petition.The Idaho Supreme Court reviewed whether the district court erred in denying Eaton’s motion to reduce her charge and her motion to correct an illegal sentence. The Court held that the commercial burglary statute was not retroactive and did not apply to Eaton’s conduct, as there was no clear legislative intent for retroactivity. The Court also determined that the commercial burglary statute created a new offense with distinct elements from the general burglary statute, and thus, Eaton was properly charged under the existing felony burglary statute. Consequently, Eaton was not entitled to the lesser penalty of the commercial burglary statute, and her sentence under the felony burglary statute was not illegal.The Idaho Supreme Court affirmed the district court’s judgment of conviction and the denial of Eaton’s Rule 35(a) motion. View "State v. Eaton" on Justia Law

Christina Greenfield appealed an order designating her as a vexatious litigant under Idaho Court Administrative Rule 59(d). The order, issued by then Administrative District Judge Cynthia K.C. Meyer, prohibits Greenfield from filing any new pro se litigation in Idaho without court permission. Greenfield had filed a civil suit for damages in Kootenai County related to the sale of her home and her eviction, naming several defendants. During this lawsuit, the defendants moved to designate Greenfield as a vexatious litigant, which the ADJ granted.In the lower court, Greenfield had previously sued her neighbors and her former attorney, both cases resulting in adverse judgments against her. She also declared bankruptcy, leading to the sale of her home. Greenfield filed another lawsuit against the new owners of her home and others, which led to the motion to declare her a vexatious litigant. The ADJ found that Greenfield had maintained at least three pro se litigations in the past seven years that were decided adversely to her and issued a Prefiling Order. Greenfield responded to the proposed order, but the ADJ issued an Amended Prefiling Order, finalizing the vexatious litigant designation.The Idaho Supreme Court reviewed the case and affirmed the ADJ’s decision. The Court held that the ADJ did not abuse her discretion in refusing to disqualify herself, as there was no evidence of personal bias. The Court also found that the ADJ followed the proper procedures under Idaho Court Administrative Rule 59, providing Greenfield with adequate notice and opportunity to respond. The Court concluded that Greenfield was afforded due process and that the ADJ’s findings were supported by sufficient evidence, confirming that Greenfield had maintained multiple litigations that were adversely determined against her. View "Greenfield v. Meyer" on Justia Law

Steven Chase appealed the district court’s denial of his motion for a directed verdict on a claim for tortious interference with prospective economic advantage. The claim arose from a failed real estate transaction between Steven’s mother, Audrey Chase, and Streamline Builders, LLC, owned by Richard Swoboda, for the construction of a home. Steven was involved in the transaction, assisting his mother by communicating with Swoboda and realtors, and inspecting the home. The sale did not close due to disagreements over holdback amounts for uncompleted items. Following the failed closing, Streamline and Swoboda sued Steven for tortious interference.The case proceeded to a jury trial in the District Court of the First Judicial District of Idaho, Kootenai County. At the close of Streamline and Swoboda’s evidence, Steven moved for a directed verdict, arguing insufficient evidence of wrongful interference. The district court denied the motion, and the jury found in favor of Streamline and Swoboda, awarding $20,000 in damages. Steven appealed, contending the district court erred in denying his motion because he acted as his mother’s agent and could not be liable for tortious interference.The Supreme Court of Idaho reviewed the case and held that Steven failed to preserve his agency argument for appeal, as he did not present it to the district court in support of his motion for a directed verdict. The court affirmed the district court’s judgment, noting that Steven’s argument on appeal differed from his argument at trial, where he focused on the lack of improper motive rather than his agency status. The court also awarded attorney fees on appeal to Streamline and Swoboda, finding Steven’s appeal unreasonable and without foundation. View "Streamline Builders, LLC v. Chase" on Justia Law

Gerardo Raul Chavez was convicted of second-degree murder for the 2016 killing of Vason Widaman. While in custody for a probation violation, Chavez made incriminating statements to a cellmate, Manuel Acevedo, who was acting as a confidential informant. The State sought to introduce these recordings at trial. Chavez moved to suppress the statements, but the district court only partially granted the motion, suppressing a few statements. The jury acquitted Chavez of first-degree murder but convicted him of second-degree murder with a firearm enhancement. Chavez was sentenced to an indeterminate life sentence with a 42-year fixed term. Post-trial, Chavez's motions for a new trial and permission to contact jurors were denied.Chavez appealed, arguing that the district court erred in denying his motion to suppress, abused its discretion in sentencing, violated his constitutional rights by considering acquitted conduct at sentencing, and erred in denying his motion to contact jurors. The Idaho Supreme Court reviewed the case.The Idaho Supreme Court affirmed the district court's decision. It held that the district court did not err in admitting Chavez's statements, as they were not deliberately elicited by Acevedo. The court also found no abuse of discretion in the 42-year fixed sentence, noting that it fell within statutory limits and was justified by the aggravating factors. The court further held that considering acquitted conduct at sentencing did not violate Chavez's constitutional rights. Finally, the court found no abuse of discretion in denying the motion to contact jurors, as Chavez failed to show good cause for suspecting juror misconduct. View "State v. Chavez" on Justia Law

Michael Anthony Pulizzi was convicted of felony possession of methamphetamine and destruction, alteration, or concealment of evidence. Pulizzi argued that the district court erred in denying his motion to suppress evidence obtained from warrantless searches and seizures of his trash, which he claimed violated his rights under the Idaho Constitution. He contended that the Twin Falls City waste collection ordinances created an objectively reasonable expectation of privacy in his trash.The District Court of the Fifth Judicial District of Idaho denied Pulizzi’s motion to suppress, finding that the waste collection ordinance did not create a reasonable expectation of privacy. The court concluded that the ordinance did not mandate participation in the city’s waste collection program and that the prohibition against collecting garbage for monetary gain did not apply to law enforcement officers. Pulizzi then pled guilty to the charges under a conditional plea agreement, preserving his right to appeal the suppression ruling.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court’s judgment. The court held that the waste collection ordinance did not create an objectively reasonable expectation of privacy in Pulizzi’s trash. The court declined to reconsider its previous holdings in State v. Donato and State v. McCall, which aligned with the U.S. Supreme Court’s decision in California v. Greenwood, stating that there is no reasonable expectation of privacy in garbage left for collection in a public area. The court found that the ordinance’s purpose was to promote public health and safety, not to protect privacy interests in curbside garbage. Consequently, the court affirmed Pulizzi’s conviction. View "State v. Pulizzi" on Justia Law

Four former employees of Litster Frost Injury Lawyers (LFIL) filed a lawsuit against LFIL and its former sole shareholder, Martha Frost, for unpaid wages and breach of an employment agreement. They claimed LFIL owed them compensation in the form of wages, bonuses, profit sharing, and other expenses incurred while employed. The district court granted summary judgment in favor of LFIL, concluding that the employees' claims were time-barred by the one-year statute of limitations under Idaho Code section 45-614 and that the employment agreement was an unenforceable "agreement to agree."The employees appealed, arguing that the district court erred in determining that the provisions of the employment agreement were not severable or enforceable and that the court should have supplied a "reasonable time" for performance. LFIL cross-appealed, arguing that the district court erred in denying their request for attorney fees following summary judgment.The Supreme Court of Idaho reviewed the case and held that the district court did not err in granting summary judgment on the employees' breach of contract claims because the employment agreement was unenforceable. The court found that the agreement's essential terms were too indefinite and subject to future negotiations. However, the court reversed the district court's decision regarding Sarah's reimbursement claim, finding that issues of material fact existed as to whether her claim fell within Idaho's Wage Claim Act. The court affirmed the district court's grant of summary judgment on all other claims.The Supreme Court also reversed the district court's decision on attorney fees, holding that the district court did not apply the correct legal standard. The court remanded the case for further proceedings consistent with its opinion. Attorney fees on appeal were awarded to LFIL for the time spent responding to certain claims, and costs were awarded to LFIL. View "Litster v. Litster Frost Injury Lawyers PLLC" on Justia Law