Justia Idaho Supreme Court Opinion Summaries

Patricia Amstutz appealed her conviction for driving under the influence of alcohol (“DUI”). Amstutz argued the district court erred in denying her motion to suppress because she was arrested, without a warrant, for a completed misdemeanor offense that occurred outside of the officer’s presence. She claimed that her rights under the Idaho Constitution based on the Idaho Supreme Court’s decision in Idaho v. Clarke, 446 P.3d 451 (2019) were violated. After review, the Supreme Court reversed the district court’s order denying Amstutz’s motion to suppress, vacated her judgment of conviction, and remanded the case for further proceedings. View "Idaho v. Amstutz" on Justia Law

In 2015, Ralph Isom filed for bankruptcy. Ultimately, a bankruptcy trustee for the estate settled with Isom’s primary creditor, Farms, LLC (“Farms”). As part of the settlement, the bankruptcy trustee conveyed a ten-acre parcel from the bankruptcy estate to Farms. Isom was living on the ten-acre parcel at the time. When Isom refused to vacate the ten-acre parcel, Farms initiated this forcible detainer action. The magistrate court entered judgment for Farms and ordered Isom to vacate the ten-acre parcel. Isom appealed to the district court, but also vacated the property as the magistrate court had ordered. Because Isom had vacated, and thus no longer occupied or owned the ten-acre parcel, the district court held that Isom’s appeal was moot. Further, the district court rejected the merits of Isom’s appeal. Isom appealed the district court’s decision on the merits, but failed to appeal the district court’s holding that his appeal was moot. The Idaho Supreme Court found that because Isom failed to raise, let alone argue against, the district court’s decision as it related to mootness, the issue was considered waived."Isom’s waiver is dispositive. As a result, we will not reach the merits of his appeal as it relates to the sufficiency of proof regarding the forcible detainer action." Judgment was thus affirmed. View "Farms, LLC v. Isom" on Justia Law

The United States Court of Appeals for the Ninth Circuit certified a question of law to the Idaho Supreme Court. The federal court asked whether an Idaho state court order reducing a defendant’s judgment of conviction for felony burglary to a judgment of conviction for misdemeanor petit theft under Idaho Code 19-2604(2) changed the operative conviction for the purposes of Idaho Code 18-310, which prohibited the restoration of firearm rights to those citizens convicted of specific felony offenses. In 2019, defendant Antonio Gutierrez was indicted in the District of Montana on four charges: (1) conspiracy to commit robbery affecting commerce; (2) robbery affecting commerce; (3) possession of a firearm in furtherance of a crime of violence; and (4) felon in possession of a firearm. These charges resulted from a robbery of Dotty’s Casino in Billings, Montana, that involved a firearm. The felon in possession of a firearm charge stemmed from Gutierrez’s previous convictions under Idaho state law for burglary. In 2000, Gutierrez pleaded guilty to two counts of felony burglary. He was sentenced to the Idaho State Correctional Institution for a fixed term of two years and a subsequent indeterminate term of three years. In 2003, acting pursuant to Idaho Code section 19-2604(2), an Idaho district court ordered Gutierrez’s burglary convictions “REDUCED to Misdemeanor Petit Theft.” The order specified that Gutierrez was “not to be considered a convicted felon because he has successfully complied with the terms and conditions of probation and paid all restitution/reimbursement and fines in full.” Based on the plain language of Idaho Code section 19-2604 the Idaho Supreme Court's answer to the Ninth Circuit’s question was no. "A grant of leniency under Idaho Code section 19-2604(2) does not remove a defendant originally convicted of an enumerated felony from the reach of section 18-310(2) and (3)." View "United States v. Gutierrez" on Justia Law

The issue presented for review by the Idaho Supreme Court stemmed from an “unfortunate kitchen accident.” Mary Clare Griffin purchased a bottle of Italian wine, which broke in her hands as she attempted to open it, causing substantial injuries. Griffin and her son, a minor who witnessed the event, brought a product liability suit against Zignago Vetro S.P.A., the Italian manufacturer of the wine bottle; Marchesi Antinori SRL (Antinori), the Italian wine company that purchased the bottle from Zignago, filled it with wine, and exported it to the United States; Chateau Ste. Michelle Wine Estates, Ltd. (Ste. Michelle), the United States importer; S & C Importers and Distributors, Inc. (S&C), the Idaho distributor who purchased the bottle from Ste. Michelle; and, Albertson’s LLC (Albertson’s), the retailer that sold the bottle to Griffin. Zignago successfully moved the district court to dismiss Griffin’s complaint based on a lack of personal jurisdiction. Griffin appealed the district court’s decision, asking the Supreme Court to apply the personal jurisdiction framework established by the United States Supreme Court in World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980). Zignago claimed the district court did not err by applying the stricter test that the United States Supreme Court offered in Asahi Metal Indus. Co. v. Superior Court of California, Solano Cnty., 480 U.S. 102 (1987) (plurality). Griffin also appealed several adverse discovery rulings. The Supreme Court held that the correct test when determining personal jurisdictional issues remains the “stream of commerce” test adopted by the United States Supreme Court in World-Wide Volkswagen. Applying that test to the case here, the Court reversed the district court’s decision to grant Zignago’s motion to dismiss for lack of personal jurisdiction and remand the case for further proceedings. Furthermore, the Court affirmed the district court’s decision granting Antinori’s and Ste. Michelle’s motions for summary judgment and hold that it did not abuse its discretion in failing to grant Griffin’s motion to compel discovery against Antinori and Ste. Michelle. View "Griffin v. Ste. Michelle Wine Estates LTD." on Justia Law

Timothy Dacey was convicted by jury of Driving Under the Influence (“DUI”). He received a second offense sentencing enhancement. During his trial, the magistrate judge allowed Officer Jessica Raddatz, a trained drug recognition expert, to testify as a lay witness about the physical indicators that a person is on the “downside” from methamphetamine use. On intermediate appeal, the district court affirmed. Dacey argued the district court erred in affirming his conviction and sentence because: (1) the “downside” testimony qualified as expert witness testimony, which should have been disclosed in discovery; and (2) the magistrate court failed to conduct the appropriate analysis to determine whether this alleged expert witness testimony was admissible. Dacey also argued the district court on intermediate appeal applied the wrong legal standard in determining that any error was harmless. After review, the Idaho Supreme Court concluded the district court erred in upholding the magistrate court’s ruling that allowed Raddatz to testify as a lay witness. Accordingly, the Court reversed and remanded this case to the district court with direction to vacate Dacey’s judgment of conviction and remand it to the magistrate court for further proceedings. The Court also announced that, henceforth, trial testimony from a drug recognition expert requires expert witness disclosure in accordance with Idaho Criminal Rule 16(b)(7). View "Idaho v. Dacey" on Justia Law

Douglas Waite appealed an Idaho Industrial Commission (“Commission”) decision requiring him to repay unemployment benefits he received, along with interest and penalties. Waite claimed the Commission’s determination that he willfully misstated a material fact for the purpose of obtaining unemployment benefits was not supported by substantial and competent evidence and was incorrect as a matter of law. Additionally, Waite argued the Commission erred when it concluded that Idaho Code section 72-1366(12) required him to repay the unemployment benefits he received. Finding no reversible error, the Idaho Supreme Court affirmed the Commission’s decision and order. View "Waite v. Moto One KTM, LLC" on Justia Law

Medical Recovery Services, LLC, (MRS) sued Michael Eddins to collect on debts that had purportedly been assigned to MRS by Intermountain Emergency Physicians and Intermountain Anesthesia. After a bench trial, the magistrate court dismissed MRS’s complaint, holding MRS lacked standing because it failed to prove a valid assignment occurred. MRS appealed to the district court. That court reversed, holding the magistrate court erred in limiting the admission of two exhibits that MRS relied upon to establish that Eddins’ accounts had been validly assigned to it. Alternatively, the district court held Eddins was judicially estopped from raising the assignment issue at trial because he did not raise it earlier during the litigation. Eddins timely appealed to the Idaho Supreme Court. After review, the Court affirmed the district court’s decision on the magistrate court’s abuse of discretion in limiting the admission of "Exhibit 2." The Court likewise affirmed the district court’s conclusion about an agent of MRS and its standing for the purposes of prosecuting this case. The Court reversed as to all other issues and remanded for further proceedings. View "Medical Recovery Svcs v. Eddins" on Justia Law

In 2018, Marissa Dempsey was convicted by a jury of several counts of burglary, grand theft, and petit theft, after which the district court entered an order requiring Dempsey to pay restitution to the victims of the crimes. Dempsey appealed on three grounds: (1) her conviction on one count of grand theft should have been reduced to petit theft because conviction for grand theft required the State to prove the stolen property was worth more than $1,000, which she alleged the State failed to do; (2) the prosecuting attorney committed prosecutorial misconduct by making several improper statements during closing arguments that constituted fundamental error, thereby entitling her to a new trial; and (3) the district court erred in ordering restitution for several items stolen from the victims. With regard to certain jewelry, electronics, coin collections, and other property, Dempsey contended the district court erred because the State failed to present substantial evidence to establish the market value of the property at the time of the crime. Regarding restitution for the cost to replace a stock certificate and three certified marriage certificates, Dempsey argued the district court erred because the victim had not actually incurred the cost of replacing the documents before sentencing. While the Idaho Supreme Court affirmed Dempsey's conviction on all counts, it concurred with her latter argument that it was error to order restitution for a stolen coin collection and perfume, and in awarding restitution for the replacement cost of stock and marriage certificates. View "Idaho v. Dempsey" on Justia Law

Kevin Cox was charged by information with attempted strangulation and intentional destruction of a telecommunication instrument stemming from the domestic abuse of his wife. The crime of attempted strangulation was a felony punishable by up to fifteen years imprisonment; intentional destruction of a telecommunication instrument was a misdemeanor punishable by up to one year imprisonment. Cox plead not guilty to both charges. The State then filed an Information Part II, alleging that Cox was a persistent violator under Idaho Code section 19-2514 because he had been convicted of three prior felonies. Conviction under section 19-2514 carried a sentence of not less than five years and up to life imprisonment, irrespective of the penalty prescribed for the underlying offense. Cox made no objection to the composition of the jury after it was selected. However, he was never asked if he passed the jury for cause, apparently due to an oversight by the district court after an interruption during voir dire. As a result, Cox never passed the panel for cause. The jury found Cox guilty on both charges and Cox admitted to being a persistent violator. The district court imposed a ten-year sentence with three years fixed for the attempted strangulation conviction, a concurrent sixty-day sentence for the destruction of a telecommunication instrument conviction, and retained jurisdiction. After a rider review hearing, the district court suspended Cox’s sentence and placed Cox on probation for ten years. Cox appealed. The Idaho Supreme Court found the district court erred in denying Cox ten peremptory challenges during voir dire. Idaho Criminal Rule 24 provided: “If the offense charged is punishable by death, or life imprisonment, each party . . . is entitled to 10 peremptory challenges. In all other felony cases each party. . . is entitled to six peremptory challenges.” Cox maintained he was entitled to ten challenges because this provision focused on the maximum possible punishment that a defendant could face if convicted, while the State maintained that the legislatively prescribed penalty for the underlying offense controlled, without regard to any potential enhancement. The Supreme Court concluded Cox was entitled to a new trial because, by this opinion, the Court adopted a new standard for demonstrating error from the denial of a peremptory challenge. Judgment was vacated and the case returned to the trial court for further proceedings. View "Idaho v. Cox" on Justia Law

The issue this appeal presented for the Idaho Supreme Court's review centered on whether Shelaina Neimeyer’s argument concerning judicial notice of a municipal ordinance was properly preserved for appeal. An employee at a gas station in Twin Falls, Idaho, contacted the police about a vehicle that had been parked at the gas station for over an hour. The employee reported that a woman who had previously purchased alcohol at the gas station (later identified as Neimeyer) had not moved from the vehicle for over 30 minutes. Consequently, Officers Tracy Thompson and Candace Comeau were dispatched at approximately 2 a.m. to conduct a welfare check. When the officers approached Neimeyer's vehicle, Officer Comeau then asked Neimeyer about a small, closed container on the passenger seat. Neimeyer initially refused to allow the officers to search the container, but she acquiesced, and the officers smelled the odor of marijuana inside. After Officer Thompson asked Neimeyer to exit her vehicle, she complied and took her purse with her. Neimeyer was placed in handcuffs and told she was being detained because of the alcohol found in her vehicle, the marijuana found in the container, and the possibility that she may be under the influence of drugs or alcohol. Officer Thompson then searched Neimeyer’s purse and discovered incriminating evidence, including methamphetamine, marijuana, and drug paraphernalia. After Neimeyer was charged with possession of methamphetamine, marijuana, and drug paraphernalia, she filed a motion to suppress evidence, contending the district court erred when it denied her motion because: (1) the State did not prove the existence of a City of Twin Falls ordinance; and (2) the district court was precluded from taking judicial notice of a municipal ordinance. Because Neimeyer raised her argument concerning judicial notice for the first time on appeal, the Idaho Supreme Court affirmed the district court’s decision. View "Idaho v. Neimeyer" on Justia Law