Justia Idaho Supreme Court Opinion Summaries

The Estate of Frances Elaine Warren entered into a purchase and sale agreement with Tricore Investments, LLC involving real property near Priest Lake in Bonner County, Idaho. Before closing, the Estate sold the property to other buyers: John Stockton and Todd Brinkmeyer. Tricore filed a complaint against the Estate for breach of contract and violation of the Idaho Consumer Protection Act (“ICPA”), among other things, and sought specific performance of the purchase and sale agreement. The complaint also alleged that Stockton and Brinkmeyer tortiously interfered with the purchase and sale agreement and that the Estate, Stockton, and Brinkmeyer (collectively, “Appellants”) engaged in a civil conspiracy. The case proceeded to a bench trial where the district court found: (1) the purchase and sale agreement between the Estate and Tricore constituted a valid and enforceable contract; (2) the Estate breached the contract when it sold the property to Stockton and Brinkmeyer; (3) the Estate’s actions violated the ICPA; (4) Stockton and Brinkmeyer tortiously interfered with the contract; and (5) Appellants engaged in a civil conspiracy. The district court ordered specific performance of the contract but declined to award any additional damages. The Estate and Stockton jointly appealed; Brinkmeyer appealed separately. The Estate argued the purchase and sale agreement was not a valid, enforceable contract because it violated the statute of frauds and there was no meeting of the minds. In the alternative, the Estate argued it did not breach the contract because Tricore repudiated it, and it did not violate the ICPA. Stockton and Brinkmeyer argued they did not tortiously interfere with the purchase and sale agreement. Together, Appellants argued they did not engage in a civil conspiracy. The Idaho Supreme Court affirmed the district court’s grant of summary judgment for Tricore on the Estate’s statute of frauds defense. The Court also affirmed the district court's findings that: (1) the Estate breached the Tricore PSA; (2) the Estate violated the ICPA; and (3) Stockton and Brinkmeyer tortiously interfered with the Tricore PSA. The district court's finding that Appellants engaged in a civil conspiracy was reversed. As a result, the attorney fee award was affirmed only as it applied to the Estate from fees against Stockton and Brinkmeyer. Tricore was not entitled to monetary damages on the tortious interference claim. View "Tricore Investments LLC v. Estate of Warren" on Justia Law

Cases consolidated for review by the Idaho Supreme Court were appeals of three separate judgments ejecting three non-beneficiary parties from the property of an estate. The personal representative of the Estate of Victoria H. Smith (“the Estate”) brought three separate ejectment actions against the Law Office of Vernon K. Smith, LLC, and Vernon K. Smith Law, PC (collectively “VK Law”); David R. Gibson; and Vernon K. Smith, III (“Vernon III”), after each party refused his demands to vacate their respectively occupied properties. None of the parties were beneficiaries of the Estate. The district courts granted partial judgment on the pleadings in favor of the personal representative in all three actions, entering separate judgments ejecting Gibson, Vernon III, and VK Law from the Estate’s properties. On appeal, Appellants raised numerous issues relating to the personal representative’s authority to eject them from the properties. Ford Elsaesser, the personal representative of the Estate, argued on appeal that the district courts did not err in granting partial judgment on the pleadings because he had sufficient power over Estate property to bring an ejectment action on the Estate’s behalf. Finding no reversible error, the Supreme Court affirmed the district court. View "Elsaesser v. Gibson" on Justia Law

During a traffic stop, police confiscated a pipe, a bong, and some marijuana possessed by defendant-appellant Richard Heath. Heath was charged with misdemeanor possession of marijuana and misdemeanor possession of drug paraphernalia. Heath moved to suppress the pipe and bong as evidence against him and the magistrate court granted the motion. Heath also moved for the return the pipe and the bong under Idaho Criminal Rule 41(f), but the magistrate court denied the motion after holding that the pipe and bong were contraband. Heath appealed the denial of his motion to the district court, which affirmed. Finding no reversible error, the Idaho Supreme Court also affirmed. View "Idaho v. Heath" on Justia Law

Defendant-respondent Dale Sutterfield stole a cell phone owned by a restaurant in Garden City, Idaho. A restaurant employee and his co-worker confronted Sutterfield, recovered the cell phone, and subsequently contacted the Garden City police for assistance. After the police arrived, the restaurant employee signed an affidavit and citizen’s arrest form. The police arrested Sutterfield for petit theft and conducted a search incident to arrest. During their search, the police found a small quantity of methamphetamine. Sutterfield was also arrested for felony possession of a controlled substance. Sutterfield moved to suppress the methamphetamine evidence, asserting his arrest and the search incident to that arrest violated his rights under the Fourth Amendment to the United States Constitution and Article I, Section 17 of the Idaho Constitution. After determining that Sutterfield had been arrested by a peace officer for a completed misdemeanor that occurred outside of the officer’s presence in violation of the Idaho Constitution, the district court granted Sutterfield’s motion to suppress. The district court dismissed the felony count of possession of a controlled substance, and Sutterfield pleaded guilty to the misdemeanor count of petit theft. The State timely appealed dismissal of the felony charge. The Idaho Supreme Court reversed, finding that the citizen’s arrest did not offend the Idaho Constitution, and defendant's arrest was not one by a peace officer for a completed misdemeanor that occurred outside of the officer’s presence. Therefore, the Court held the search-incident-to-an-arrest exception applied. Police were not precluded from conducting a warrantless search of Sutterfield after placing him under citizen’s arrest. Moreover, the evidence obtained by the officer during the search incident to the citizen’s arrest was not subject to the exclusionary rule. Therefore, the district court erred when it granted Sutterfield’s motion to suppress. View "Idaho v. Sutterfield" on Justia Law

In 2004, a jury found Azad Haji Abdullah guilty of first-degree murder, first-degree arson, three counts of attempted first-degree murder, and felony injury to a child. He was sentenced to death for the murder. Abdullah filed a petition for post-conviction relief, which was dismissed by the district court in 2011. Abdullah then filed a consolidated appeal that included a direct appeal from his convictions and sentences and an appeal from the district court’s dismissal of his petition for post-conviction relief. The Idaho Supreme Court, in Idaho v. Abdullah, 348 P.3d 1 (2015), affirmed the convictions, sentences, and denial of post-conviction relief. In 2013—after the district court issued its order dismissing the petition for post-conviction relief, but prior to the Supreme Court’s issuance of Abdullah in 2015—Abdullah filed a successive petition for post-conviction relief. The Successive Petition was amended in 2016 and 2017. Abdullah also filed a pro se supplement to the successive petition that was incorporated with the successive petition. The successive petition and supplement included substantive claims, claims of ineffective assistance of trial counsel, and claims of ineffective assistance of appellate counsel. The district court determined that Abdullah was not entitled to post-conviction relief and summarily dismissed his successive petition and Supplement. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s dismissal. View "Abdullah v. Idaho" on Justia Law

The plaintiffs were indigent defendants represented in criminal actions by attorneys provided through Idaho’s public defense system. They alleged that numerous inadequacies in Idaho’s public defense system, as administered by the State and the Idaho Public Defense Commission (“PDC” or together “Respondents”), violated the rights of the named plaintiffs, as well as those of similarly situated criminal defendants across Idaho, under the Sixth and Fourteenth Amendments to the U.S. Constitution and Article I, Section 13 of the Idaho Constitution. In 2019, the district court denied cross motions for summary judgment, citing a lack of precedent as to the controlling legal standard to be applied, and requested this appeal. The Idaho Supreme Court granted the district court’s request for permissive appeal to determine the standard of review. The central issue presented for the Supreme Court's review centered on how to properly evaluate the deficiencies in Idaho’s public defense systems alleged by Appellants. In sum, Appellants insisted that a broader view was sufficient, while Respondents demanded the district court examine this issue closely. The Supreme Court held that both views were necessary: "a close up view, which allows for greater specificity, must be applied to the individual claims of at least one of the named plaintiffs whose allegations formed the basis of standing; however, a more distant view, which allows for greater overall perspective, is permissible for the examination of the systemic constitutional shortcomings alleged by Appellants." View "Tucker v. Idaho" on Justia Law

Massimo Medioli petitioned an Idaho magistrate court to change his minor child’s name. The child’s mother, Dena Hayes, objected. The magistrate court granted Medioli’s petition finding the name change to be “right and proper,” as provided by Idaho Code section 7-804. Hayes appealed to the district court, and the district court affirmed. The district court awarded Medioli attorney fees pursuant to Idaho Code section 12-121. Hayes appealed, arguing in part that trial courts were required to apply the best-interest-of-the-child standard in disputed name change cases involving minor children. The Idaho Supreme Court found no reversible error in the district court’s decision on the merits, but reversed the award of attorney fees. View "Hayes v. Medioli" on Justia Law

While responding to a call regarding an ongoing robbery at a mobile home park in Grangeville, Idaho, officers with the Grangeville Police Department interacted with defendant-appellant William Clark. Upon learning that Clark had an outstanding warrant for his arrest in Nez Perce County, Idaho, the officers attempted to arrest him. Clark fled, first entering a nearby home where the owner of the home implored him to leave. After exiting the first home, Clark entered the home next door, successfully evading the officers for approximately ten minutes. The officers eventually located Clark, hiding underneath a bed in the second home, where he was arrested. After a bench trial, the district court found Clark guilty on both counts of felony unlawful entry, concluding that the officers’ pursuit to execute the arrest warrant constituted “fresh pursuit” as defined in Idaho Code section 19-705. Clark appealed, arguing that pursuit to execute an outstanding warrant did not fall under either the common law or statutory definition of “fresh pursuit.” As a result, Clark argued the State failed to present sufficient evidence of the pursuit element for felony unlawful entry. Finding that "fresh pursuit," as defined in section 19-705 included pursuit to execute an arrest warrant, the Idaho Supreme Court affirmed Clark's conviction. View "Idaho v. Clark" on Justia Law

Defendant Melonie Smith appealed her conviction for first degree murder and destruction, alteration, or concealment of evidence. On appeal, Smith claimed the district court: (1) erred when it denied her motion to suppress; (2) abused its discretion when it admitted certain testimony over her objection; and (3) committed fundamental error by (a) admitting a video and (b) not striking the prosecutor’s comments in closing arguments. Smith further argued she was deprived of her right to a fair trial due to the accumulation of errors. Finding no reversible error, the Idaho Supreme Court affirmed her convictions. View "Idaho v. Smith" on Justia Law

In 2013, Tech Landing, LLC leased a building to JLH Ventures, LLC (“JLH”) to operate a paintball business. After the building burned down in 2017, Tech Landing sued JLH, alleging breach of contract, breach of the covenant of good faith and fair dealing, and negligence. The breach of contract and breach of the covenant of good faith and fair dealing claims involved payment of rent after the building was destroyed and the failure to insure the building against fire loss. Those claims were dismissed by stipulation of the parties and were not at issue here. With respect to its negligence claim, Tech Landing alleged the fire was caused by the negligence of JLH. After ruling certain opinions of Tech Landing’s expert witnesses were inadmissible, the district court granted summary judgment to JLH. After review, the Idaho Supreme Court affirmed the district court’s ruling on the admissibility of the expert opinions, but reversed its grant of summary judgment because there were genuine issues of material fact that had to be decided by a jury. View "Tech Landing LLC v. JLH Ventures LLC" on Justia Law