Justia Idaho Supreme Court Opinion Summaries

The issue this case presented for the Idaho Supreme Court's review centered on a waste ditch that drained surface water from property owned by Lora Roberts through property owned by Thomas and Deanna Jensen (the Jensens). The ditch itself passed through a man-made culvert under a county road between the properties. The Jensens filled in the portion of the waste ditch located on their property in 2013. In February 2017, Roberts’ property experienced significant flooding. The flooding damaged her home as well as horse feed stored in the barn. It also forced her to relocate her horses from her property. Roberts filed an action against the Jensens, alleging trespass and nuisance, as well as seeking a declaratory judgment to establish that Roberts had an interest in the waste ditch on the Jensens’ property as an easement on the basis that the ditch was an established natural servitude. The district court ultimately granted the Jensens’ motion for summary judgment against Roberts, and denied Roberts’ motion for summary judgment. The district court also dismissed the nuisance claim because the flooding was not caused by a natural servitude, and therefore a nuisance action was not applicable. The district court then denied Roberts’ request for a declaratory judgment. Roberts moved unsuccessfully for reconsideration, and her appeal followed. After review of the trial court record, the Supreme Court affirmed the district court’s order granting summary judgment against Roberts. View "Roberts v. Jensen" on Justia Law

This appeal involved the enforceability of a premarital agreement between Julie Neustadt and Mark Colafranceschi. Before the two were married, they entered into a premarital agreement that required Neustadt to obtain a two-million-dollar life insurance policy naming Colafranceschi as the beneficiary. The agreement required Neustadt to keep the policy in force after termination of the marriage. During the divorce proceedings, Neustadt challenged the enforceability of this provision, arguing that the insurance clause was void as against public policy to the extent it applied after divorce. The magistrate court agreed that the contractual provision was void as against public policy. However, on appeal, the district court reversed, concluding the insurance clause did not violate any public policy in Idaho. Neustadt appealrf, arguing that the district court erred in finding the insurance clause valid and enforceable because, following the parties’ divorce, Colafranceschi had no insurable interest in Neustadt’s life. Colafranceschi also filed a cross-appeal, arguing: (1) the magistrate court erred in denying certain discovery requests; (2) the lower court erred by failing to address his objection to Neustadt’s motion in limine; and (3) the lower courts’ erred in their findings that Colafranceschi failed to prove he was fraudulently induced to sign the premarital agreement to get him to return to the couple’s marital home. The Idaho Supreme Court affirmed the district court decision in its entirety: (1) the Insurance Clause was not void as against public policy; (2) any error regarding discovery was forfeited; (3) there was no evidence that the magistrate court coerced Colafranceschi into withdrawing his extreme cruelty claim; and (4) substantial and competent evidence supported the magistrate court’s conclusions that Colafranceschi was not fraudulently induced regarding equity in the Osprey home. View "Neustadt v. Colafranceschi" on Justia Law

In 2015, the Kenworthys began construction on a two-story boat garage on Lake Coeur d’Alene. The Newtons’ property overlooked the location of the Kenworthys’ boat garage. The new structure was much larger than the original boat garage and had a second floor. After construction began, the Newtons took issue with the size of the new structure, and sued the Idaho Department of Lands (IDL) and the Kenworthys’ related family entities (the LLC Respondents), asserting claims of public and private nuisance and requesting injunctive relief to mandate the removal of the offending structure. The parties filed cross-motions for summary judgment. The district court held that the Newtons failed to establish that the boat garage was illegal and that their nuisance claims failed as a matter of law. The district court subsequently entered judgments in favor of IDL and the LLC Respondents. After the district court denied the Newtons’ motion for reconsideration, the Newtons appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Newton v. MJK/BJK MBK Lake" on Justia Law

Defendant-respondent Jennie Pylican moved to suppress evidence she unlawfully possessed methamphetamine and drug paraphernalia on the evening of October 12, 2017. At that time, an officer observed Pylican enter a storage facility after hours. When she left, the officer followed and observed her make a turn without signaling. Pylican was initially stopped for the traffic violation and later questioned about her presence in a storage facility after hours. The district court granted the motion, holding that the arresting officer unconstitutionally extended the stop when he questioned Pylican regarding her presence in the storage facility. In the alternative, the district court ruled that the officer unconstitutionally extended both the scope and duration of the seizure by requiring Pylican to exit her car. In an unpublished opinion, the appellate court affirmed the district court’s order granting Pylican’s motion to suppress, holding that the officer did not provide any evidence of suspicious activity at the storage facility that would justify Pylican’s extended detention on that basis. On appeal to the Idaho Supreme Court, the State argued the district court erred in grantion Pylican's motion because: (1) the deputy had reasonable suspicion to question Pylican regarding her presence in the storage facility; and (2) the deputy’s order to exit the vehicle did not unconstitutionally extend the duration of the stop. After review of the district court record, the Supreme Court reversed the district court’s order and remanded for further proceedings. View "Idaho v. Pylican" on Justia Law

Royal Von Puckett made the winning $100 bid at a sheriff’s sale for two unsatisfied divorce judgments totaling over $230,000. His attorney, Vernon Smith, was the judgment debtor on both judgments. Sharon Bergmann, Smith’s ex-wife, was the judgment creditor on both judgments. The district court concluded that the sale should have been set aside because of grossly inadequate consideration and procedural irregularities associated with the sale. Puckett appealed that order. Finding the district court did not abuse its discretion in setting aside the sheriff's sale, the Idaho Supreme Court affirmed. View "Puckett v. Bergmann" on Justia Law

In September 2018, Idaho State Police Sergeant Curt Sproat pulled over a vehicle driven by defendant-respondent Cody Hansen on Interstate 90 after observing a traffic infraction. As Sergeant Sproat approached the vehicle on the passenger side, he saw a passenger in the back seat making “furtive movements.” Sergeant Sproat asked Hansen for his license and registration and requested identification from the passengers. Hansen provided his license, but informed Sergeant Sproat that he had not yet registered the vehicle and did not know his home address. He also told Sergeant Sproat that he was on felony probation. Hansen declined to give consent to Sergeant Sproat to search the vehicle. After his conversation with Hansen, Sergeant Sproat attempted to contact Hansen’s probation officer, but she was not available. Unable to get ahold of an on-call probation officer, Sergeant Sproat began drafting a citation. After a discussion with another Idaho State Police trooper, Sergeant Sproat decided to search the vehicle. During the search, Sergeant Sproat found a digital scale, a methamphetamine pipe, and eight “dime” baggies of what appeared to be methamphetamine. Based on the contraband found in the vehicle, Sergeant Sproat arrested Hansen. A grand jury indicted Hansen for possession with intent to deliver a controlled substance in violation of Idaho Code section 37-2732(a)(1)(A). Hansen moved to suppress all evidence found in the vehicle, arguing, among other things, that his vehicle was searched without a warrant in violation of the Fourth Amendment of the United States Constitution and Article I, section 17 of the Idaho Constitution. The State appealed when the district court granted Hansen’s motion to suppress. The district court determined that Hansen effectively revoked the consent to be searched he had given as a condition of his probation. The Idaho Supreme Court reversed, finding Hansen never sought to modify the Fourth Amendment waiver term of his probation agreement with the court that granted him probation. Instead, Hansen refused to provide Sergeant Sproat with consent to search his vehicle during the traffic stop. "Even assuming that Hansen intended to revoke the previously agreed to consent in his probation agreement, such an attempt was ineffective because it was not made in court. Accordingly, we conclude that the district court erred in finding that Hansen revoked the consent to be searched provided for in his probation agreement." View "Idaho v. Hansen" on Justia Law

The issue this case presented for the Idaho Supreme Court's review was the judicial review of a validation order issued by the Worley Highway District Board of Commissioners (the Highway District). The order validated Road No. 20 (also known as Sunny Slopes Road) across the Northwest and Northeast Quarters of Section 34, Township 47 North, Range 4 West, Boise Meridian, Kootenai County, Idaho. The purported road crossed properties owned by the Richel Family Trust and property owned by Jeanne Buell. The Trust did not contest the validation of the road in the Northwest Quarter of Section 34. However, the Trust requested judicial review of the validation of a portion of the road in the Northeast Quarter of Section 34. The district court affirmed the Highway District’s validation order. The Trust appealed the judicial review and affirmation, arguing the deed that purportedly conveyed the public right-of-way was void because it contained an insufficient description due to the loss of extrinsic evidence mentioned in the deed. Additionally, the Trust argued that many of the Highway District’s factual findings and legal conclusions were not supported by substantial and competent evidence. Further, the Trust argued that if the Highway District’s validation order was affirmed, it amounted to an unconstitutional taking under both the Idaho and United States constitutions. After review, the Supreme Court affirmed the district court’s order affirming the Highway District’s validation order. The Court determined the Trust could not establish an actual taking. View "Richel Family Trust v. Worley Hwy Dist" on Justia Law

Jonathon Frantz appealed a district court’s award of attorney fees entered against him and his clients, jointly and severally, as a sanction for frivolous conduct. This appeal arose from an easement dispute among family members. The land at issue was split into multiple parcels: the Tracy Parcel, the Mathis/Roll Parcel, and the Osborn Parcel. Plaintiffs Brook Tracy and Travis Mathis owned the Tracy Parcel; Plaintiffs Gailord “Cowboy” Mathis, Brook Tracy, Laura Roll, and Rebecca Stafford owned the Mathis/Roll Parcel; and David and Naomi Osborn owned the Osborn Parcel. In 2018, Plaintiffs filed a complaint against the Osborns. Frantz was Plaintiffs’ attorney. Plaintiffs claimed that more than thirty years ago they “constructed/placed a home” on the Tracy Parcel, “constructed/placed a cabin” on the Mathis/Roll Parcel, and “created a driveway” through the Osborn Parcel to access their respective properties. Plaintiffs also claimed that for more than thirty years they had openly and continuously used the driveway over the Osborn Parcel for access to the nearest public right-of-way, Highland Drive, which was the only reasonable way to reach their respective properties. Based on this use, Plaintiffs claimed that they had an easement by necessity, an easement by implication, or a prescriptive easement across the Osborn Parcel along the existing driveway. Accordingly, Plaintiffs sought a judgment from the district court declaring their rights in the driveway. The trial court denied a preliminary injunction for two reasons: (1) “the allegations in the complaint and the motion contain[ed] gross exaggerations, if not falsehoods” and “the credibility of all of the plaintiffs” was questionable; and (2) Plaintiffs could not establish entitlement to the relief demanded because they came to the hearing unprepared to support the easement theories they advanced with any competent evidence. The Osborns moved for attorney fees, leaving it to the trial court's discretion to award Rule 11 sanctions "if the [c]ourt determines that this motion was pursued frivolously." On appeal, Frantz contended the district court abused its discretion in awarding attorney fees against him personally because it: (1) failed to follow the procedural requirements set out in Idaho Code section 12-123; and (2) erroneously found that he engaged in frivolous conduct. After review, the Idaho Supreme Court concluded this matter did not present a justiciable controversy because the judgment was satisfied and Frantz did not preserve his right to appeal pursuant to Idaho Code section 10-1115. Accordingly, the Court dismissed Frantz’s appeal because the issues before the Court were moot. View "Frantz v. Osborn" on Justia Law

Angela Johnson and Patrick Murphy met online and began dating in 2014. When Angela discovered she was pregnant, she left Boise and began living with Patrick in his home in Coeur d’Alene. After the birth of their son, the parties resided together for three and a half years. Angela, desiring to end what she considered an “unhealthy relationship,” moved to Boise with the son in 2018. Shortly thereafter, Angela filed a petition in Ada County for paternity, custody, visitation, and support. Following venue being changed to Kootenai County and a trial, the magistrate court awarded the parties joint legal custody and physical custody of the child, with Patrick receiving primary physical custody unless Angela moved back to Coeur d’Alene at which point she and Patrick would share physical custody equally. In an expedited appeal, Angela contended the magistrate court’s decision was an abuse of discretion and required reversal. Finding no such abuse of discretion, the Idaho Supreme Court affirmed the magistrate court’s child custody order. View "Johnson v. Murphy" on Justia Law

In 2010, Appellant Chris Drakos loaned Respondent Garrett Sandow $200,000.00. A promissory note executed by Sandow on November 30, 2010, secured the loan. In 2018, after receiving no payments, Drakos filed a complaint seeking to collect on the Note. Sandow moved for summary judgment arguing that the statute of limitations barred the action. Drakos filed a cross-motion for summary judgment, arguing that the statute of limitations did not apply based on the Note’s clear language. The district court granted summary judgment to Sandow. Drakos moved the district court to reconsider, which the district court denied. Drakos timely appealed, arguing the district court erred in granting summary judgment for Sandow and in denying his motion for reconsideration. Finding no reversible error, the Idaho Supreme Court affirmed. View "Drakos v. Sandow" on Justia Law