Justia Idaho Supreme Court Opinion Summaries

Daniel Chernobieff appealed a district court’s decision on intermediate appeal to uphold a magistrate court’s summary dismissal of his petition for post-conviction relief. Chernobieff was convicted of a misdemeanor for driving under the influence with an excessive blood alcohol content in June 2014. After the Idaho Supreme Court upheld his conviction on direct appeal, Chernobieff filed a petition for post-conviction relief on the basis of ineffective assistance of counsel. He alleged that his defense counsel’s decision to object to testimony at a suppression hearing suggesting that the on-call magistrate could not be reached to obtain a warrant because his cell phone ringer was off was unreasonable and prejudicial. He argued that the objection to the ringer testimony prevented him from arguing at trial that the State did not have good cause for the on-call magistrate's unavailability. The magistrate court granted the State's motion for summary dismissal, reasoning the objection was an unreviewable strategic decision and would not have changed the outcome of the case. The district court, sitting in an appellate capacity, affirmed. Finding no reversible error, the Supreme Court also affirmed. View "Chernobieff v. Idaho" on Justia Law

This appeal stemmed from a dispute between the presiding officers of the Idaho Legislature and the Idaho State Treasurer. The Speaker of the Idaho House of Representatives and the President Pro Tempore of the Idaho State Sentate sought to evict Treasurer Julie Ellsworth from her current office on the first floor of the Idaho State Capitol building pursuant to Idaho Code section 67-1602(3). The office of the State Treasurer was historically located in the southeast quadrant of the Capitol Building. However, plaintiffs cited the need for more legislative space to evict the Treasurer from that historic office. The Treasurer refused to vacate, relying on a purported agreement base between the Governor and the 2007 leadership of the Idaho Legislature. Finding that the political question doctrine did not preclude it from reaching the merits of this dispute, the Idaho Supreme Court concluded Idaho Code section 67-1602(3) unambiguously authorized the presiding officers to determine the use and allocate the space within the first floor of the Capitol. The district court's denial of the Treasurer's motion to dismiss was affirmed; summary judgment in favor of the House and Senate were also affirmed. View "Bedke v. Ellsworth" on Justia Law

Janet Heath appealed a district court order and judgment that granted Angela Palmer and Taylor Real Estate’s motion for summary judgment and dismissing her claims for negligence and breach of contract. The events that brought about this case began in the fall of 2017 when Heath began looking to buy a house in Bingham County, Idaho. Heath and Palmer communicated back and forth via emails and text messages, arranging financing through a lender, and discussing property listings. They met to view several listings together, including a property owned by Donald and Shirley Ciccone. With Palmer's help, Heath made a written offer on the Ciccione property. The offer, titled "RE-21 Real Estate Purchase and Sale Agreement," indicated Palmer and Taylor Real Estate were acting as “nonagents” for Heath. Heath also signed an Agency Disclosure Brochure indicating that she was a “customer” of Palmer and Taylor Real Estate. The offer form further stated that Heath would remain a “customer” unless she entered into a written representation agreement. Heath and Palmer never signed such an agreement. The Ciccones made a counter-offer which Heath accepted. The Ciccones gave Palmer a property condition disclosure, which revealed the existence of a shared driveway agreement with a neighboring property owned by Walter and Wilma Wallace. At some point before the closing date, the title company contacted Palmer and informed her that the Driveway Agreement needed to be modified to “run with the land” before it would insure the title. Palmer contacted Mr. Wallace and informed him that Heath was trying to buy the Ciccone property but could not do so without a driveway agreement. The Wallaces and the Ciccones signed a 2018 Driveway Agreement, which was essentially the same as the 1998 Driveway Agreement except that it was “a covenant running with the land” and redefined the shared portion of the driveway. Heath and the Ciccones closed on the property, and the warranty deed and the 2018 Driveway Agreement were recorded with the Bingham County Recorder that afternoon. Heath stated in her declaration that she would not have gone through with the sale if she had known that the driveway easement had been shortened by approximately two-thirds of its original length, effectively cutting off access to the garages on her property and significantly reducing the property’s value. The proceedings in this case began in June 2018 when the Wallaces filed a petition to quiet title against Heath and another individual living in her home. The Wallaces filed their petition after a dispute with Heath regarding the dimensions and use of the shared driveway. Finding that the district court erred in concluding that there was no genuine dispute of material fact regarding whether Palmer and Taylor Real Estate violated the statutory duties owed to Heath as a “customer” under Idaho Code section 54-2086, the Idaho Supreme Court reversed the grant of summary judgment in favor of Palmer and Taylor Real Estate. View "Wallace v. Heath" on Justia Law

The State charged Keith Sarbacher with grand theft by receiving or possessing stolen property: a 2001 Dodge pickup truck. After Sarbacher’s arrest, the State inventoried and photographed the truck and then returned it to the insurance company, who then sold the truck before Sarbacher’s attorneys could examine it. Sarbacher moved the district court for dismissal, arguing that the State violated his constitutional right to due process by disposing of evidence that was material and potentially exculpatory. The district court granted Sarbacher’s motion and dismissed the State’s case. The State appealed, arguing the evidence at issue was of unknown exculpatory value and the trial court expressly found that the State had not acted in bad faith. The Idaho Supreme Court concluded after a review of the district court record, it would have been entirely speculative for the district court to conclude that any of the additional analyses Sarbacher wanted to conduct would have resulted in the discovery of any exculpatory evidence to exonerate him. "the evidentiary value of the truck as the corpus delicti of the crime was sufficiently preserved by the State through its inventorying and photographing the vehicle prior to its release to Hunt’s insurance company." The Court vacated the district court's decision and remanded for further proceedings. View "Idaho v. Sarbacher" on Justia Law

Rockne Lee Hollingsworth brought a medical malpractice claim against a local hospital and doctor in Gem County, Idaho district court. The district court found Hollingsworth lacked due diligence in failing to determine the hospital was a political subdivision, subject to the notice requirements of the Idaho Tort Claims Act (“ITCA”), and granted summary judgment for Respondents. Hollingsworth appealed, arguing the corporate filings made by the county-owned hospital created the false impression the hospital was a private corporation. Respondents contended the hospital and corporate entity, both owned by Gem County, were both subject to the ITCA because they were actually one and the same. To this, the Idaho Supreme Court concurred and reversed the district court's ruling. View "Hollingsworth v. Thompson" on Justia Law

This case arose from a DUI suspect’s request to make a phone call from jail following his arrest. The State appealed a district court order granting Jeffery Stegall’s motion to suppress blood alcohol concentration (BAC) evidence obtained from a blood draw. The district court granted Stegall’s motion after determining that his right to due process had been violated when police officers at the jail refused his request to make a phone call. The State argued on appeal that the district court erred in determining Stegall’s due process rights were violated because the officers were not acting in bad faith when they failed to allow him access to a phone. To this, the Idaho Supreme Court disagreed, holding the district court did not err in determining the jail officers violated Stegall’s right to procedural due process when, despite his requests, they failed to allow him access to a phone for the purpose of contacting an attorney until the morning following his arrest. Accordingly, the district court’s order granting Stegall’s motion to suppress evidence of BAC was affirmed. View "Idaho v. Stegall" on Justia Law

At issue before the Idaho Supreme Court in this matter was what portion of a military retirement benefit was subject to division following divorce. Specifically, the Court was asked to decide whether a 2017 amendment to the federal statutory scheme governing military retirement applied to the division of a benefit entered as part of a divorce decree in 2008 but not calculated until the husband’s retirement in 2018. The Supreme Court determined a 2017 amendment to 10 U.S.C. 1408 did not apply retroactively to alter the division of the military benefit at issue here. Furthermore, the district court did not err in concluding that the magistrate court’s mischaracterization of the 2008 divorce decree was harmless error because it did not impact the outcome of litigation. View "Bromund v. Bromund" on Justia Law

This case arose from a dispute over the ownership of Treasure Valley Manufacturing & Recycling, Inc., (“TVM”). Daniel Weitz appealed a district court order granting summary judgment in favor of David Weitz and John Tavares and declaring them the exclusive owners of TVM. The district court granted summary judgment after determining that Daniel Weitz failed to produce any evidence demonstrating a genuine dispute of material fact and that they were entitled to judgment as a matter of law. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgement. View "Weitz v. Weitz" on Justia Law

Originally, Western Pacific Timber, LLC (WPT) was solely owned by Timothy Blixseth (Blixseth). Andrew Hawes contended Blixseth hired him to be general counsel for WPT in 2005, and that when he was hired, Blixseth agreed on behalf of WPT to provide him with a severance package based on the length of his employment. After 2012, Blixseth no longer retained any ownership interest or management responsibility in WPT. When WPT terminated Hawes’ employment in 2017, Hawes asserted that he had a severance agreement in place that had been negotiated with Blixseth on behalf of WPT, by which he would receive $100,000 for each year of employment, capped at five years, for a total of $500,000. However, Hawes could not produce a signed copy of any agreement. WPT refused to pay the claimed severance pay, and instead offered a significantly smaller severance package. Hawes rejected WPT’s offer. Hawes then sued WPT for breach of contract. The case proceeded to trial on Hawes’ claim of an oral contract. Ultimately, the jury returned a special verdict finding that WPT was liable to Hawes for $500,000 in severance pay, an award which was later trebled by the district court. The district court also awarded Hawes the full amount of his requested attorney fees which constituted 35% of Hawes’ gross recovery. WPT unsuccessfully moved for a new trial. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Hawes v. Western Pacific Timber LLC" on Justia Law

Jesse Rebo shared a home with his wife in Coeur d’Alene for ten years. Due to a domestic assault conviction, Rebo had been ordered by a judge to not go within 300 feet of his wife or the family residence. Even so, about a week after the court issued the order, Rebo was seen near his wife, outside the home, by a police officer. The officer announced herself and Rebo retreated inside. The officer entered the home and arrested Rebo. Methamphetamine was ultimately found on Rebo’s person when he was booked at the jail. Rebo brought a motion to suppress that evidence, which the district court denied. The court ruled that Rebo lacked standing to challenge the officer’s warrantless entry into his residence because society would not recognize Rebo’s subjective expectation of privacy in the residence from which a valid no contact order prohibited Rebo from entering. Rebo appealed, arguing that his ownership interest in the home allowed him to exclude others, including the officer from the home. Rebo also argued no exigent circumstances existed to justify the officer’s warrantless entry, and the evidence discovered after the officer’s unlawful entry should have been suppressed as “fruit of the poisonous tree.” Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Rebo" on Justia Law