Justia Idaho Supreme Court Opinion Summaries

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

Appellants-patients Nathaniel Valencia and Emily Williams were self-pay patients who received emergency medical services at Saint Alphonsus Medical Center—Nampa, Inc. (“Saint Alphonsus”) in 2015. During their respective visits, Patients agreed to pay for “all charges incurred” for services rendered to them. Patients were billed in accordance with Saint Alphonsus’ “chargemaster” rates. Patients sought declaratory relief requesting the district court to rule Saint Alphonsus was only entitled to bill and seek collection of the reasonable value of the treatment provided to self-pay patients. Saint Alphonsus moved the district court to dismiss the complaint pursuant to Idaho Rule of Civil Procedure 12(b)(6). The district court treated the motion to dismiss as a motion for summary judgment pursuant to I.R.C.P. 12(d). Ultimately, the district court granted summary judgment for Saint Alphonsus, and Patients timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Williams v. St. Alphonsus Medical Center" on Justia Law

The Lola L. Cazier Revocable Trust (“Trust”) brought a quiet title action against Charles Drake Cazier (“Drake”) and Land Renewal Management, Inc. (“LRM”) pursuant to Idaho Code section 6-401. Drake answered separately from LRM and asserted a counterclaim against the Trust. The Trust moved to dismiss Drake’s counterclaim under Idaho Rule of Civil Procedure 12(b)(6), then filed a motion for summary judgment against both defendants. LRM also filed a motion under I.R.C.P. 12(b)(6) to dismiss the Trust’s cause of action against it. The district court granted summary judgment to the Trust and dismissed Drake’s counterclaim, awarding attorney fees against both defendants in the process. Drake and LRM appealed, arguing the district court erroneously dismissed Drake’s counterclaim and failed to properly dismiss LRM from the case. Drake and LRM also appealed the district court’s award of fees and costs, arguing several evidentiary errors and that the district court abused its discretion in awarding attorney fees. After review, the Idaho Supreme Court affirmed the district court’s grant of summary judgment for the Trust and affirmed the district court’s evidentiary rulings. View "Cazier Revocable Trust v. Cazier" on Justia Law

Jonathon Gregory appealed a district court’s award of summary judgment in favor of Richard and Eileen Stallings (collectively, “the Stallings”) in a breach-of-contract action stemming from the parties’ oral agreement to develop real property in Rexburg, Idaho. The property was sold in December 2012. Gregory, believing the Stallings wrongfully withheld a portion of the proceeds, filed a complaint in September 2017. The district court granted the Stallings’ subsequent motion for summary judgment, concluding that Gregory’s cause of action was barred by Idaho Code section 5-217’s four-year statute of limitations. After review, the Idaho Supreme Court determined the district court properly granted summary judgment to the Stallings because Gregory's cause of action was indeed barred by the statute of limitations in Idaho Code 5-217. Further, Gregory’s equitable-estoppel claim failed because he could not show that he pursued his claim in a reasonable amount of time. View "Gregory v. Stallings" on Justia Law

Victor Bliss appealed the grant of summary judgment in favor of the Minidoka Irrigation District (“MID”). Bliss filed a complaint against MID in April 2017, alleging: (1) breach of contract; (2) breach of fiduciary duty; (3) trespass; (4) declaratory relief; and (5) wrongful prosecution/infliction of extreme emotional distress. The complaint encompassed multiple events stemming from his decades-long relationship with MID. The district court granted MID’s motion for summary judgment on all claims, dismissing Bliss’s complaint for lack of notice under the Idaho Tort Claims Act, lack of standing, and failure to produce evidence. Bliss timely appealed, but finding no reversible error, the Idaho Supreme Court affirmed summary judgment. View "Bliss v. Minidoka Irrigation District" on Justia Law