Justia Idaho Supreme Court Opinion Summaries

Timothy Jones was convicted by jury of trafficking heroin and possession of drug paraphernalia. On appeal, he argued the trial court erred in admitting certain evidence regarding his probation status, a knife found in the initial police search of his person, and that the trial court abused its discretion in arriving at his sentence. Finding no reversible error, the Idaho Supreme Court affirmed Jones' conviction and sentence. View "Idaho v. Jones" on Justia Law

Richard Hess appealed an order of restitution entered against him following his guilty plea to trafficking heroin. Hess relied on the Idaho Supreme Court’s decision in Idaho v. Nelson, 390 P.3d 418 (2017), to argue that there was insufficient evidence to support all but $1,500 of the award. The Court of Appeals reversed the restitution order, and the Supreme Court granted the State’s timely petition for review. The Court determined that $500 of the district court’s award of investigation costs was unsupported by the evidence. However, the district court correctly awarded the remaining amounts of restitution because: (1) Hess failed to preserve his foundational objections; and (2) substantial evidence supported the remainder of the award. View "Idaho v. Hess" on Justia Law

After Christine Nelson quit her job at Franklin Building Supply in Pocatello, Idaho, due to what she described as a hostile and demeaning work environment, she filed for unemployment benefits with the Department of Labor. The Department denied Nelson’s request for benefits, concluding that she quit her job without good cause because “reasonable alternatives were not exhausted prior to quitting.” Nelson mailed her protest via the U.S. Postal Service (“USPS”) from Pocatello, Idaho. Her letter arrived at the Department’s offices in Boise on March 7, one day past the deadline. Because the postmark did not indicate the date of mailing, Nelson’s protest was dismissed by the Department for being untimely. After a hearing, an appeals examiner concluded that although there was a USPS postmark stamped on the envelope, the red ink “blend[ed] with the red stamps,” obscuring the date. Thus, while the distribution center could be discerned from the postmark, “the remainder of the postmark [was] illegible.” Because the envelope lacked a date on the postmark, the appeals examiner concluded that the envelope should be treated as if it had no postmark at all, thereby making the date of filing the date received, which was March 7, 2019 - one day too late. Nelson timely appealed the decision of the appeals examiner to the Industrial Commission, arguing that the letter was mailed by March 1 and that she had no control over its late arrival or the absence of a legible postmark. The Commission concurred with the appeal's examiner. The Department of Labor nor the Industrial Commission considered Nelson's reason for appealing in the first place: that she lacked good cause to leave her employment. Focusing instead on the timeliness of her appeal, the Idaho Supreme Court determined the Department and Commission were mistaken in holding Nelson's filing was too late: "since once a letter is deposited for mailing it is entirely within the control of the USPS, the obscured date on the postmark stamp could only have been a result of USPS error. Thus, by the application of reason and common sense, the delivery of this letter on March 7—even with an illegible date on the postmark—conclusively proves that Nelson must have deposited her appeals letter into USPS custody on or before the March 6 filing deadline." The decision in this matter was reversed and remanded for consideration of the merits of Nelson's case. View "Nelson v. IDOL and Franklin Group" on Justia Law

Jesus Manuel Garcia was found guilty by jury of second-degree murder, aggravated battery, use of a deadly weapon during the commission of the former crimes, and possession of a controlled substance. The district court sentenced Garcia to an indeterminate life sentence with twenty-five years fixed for second degree murder, which included a sentencing enhancement for the use of a deadly weapon. The district court also sentenced Garcia to twenty years, with six years fixed, for aggravated battery; this also included a sentencing enhancement for the use of a deadly weapon. The district court further sentenced Garcia to three years fixed for the possession of a controlled substance conviction. All three sentences were ordered to run concurrently. In addition, the district court ordered restitution to the victims in the amount of $162,285.27. Garcia timely appealed, arguing: (1) the district court abused its discretion in allowing the State to present “in-life” photos of the victim and to elicit testimony about the victim’s personality and character during trial; (2) the prosecutor committed misconduct when she referred to this challenged evidence in her closing statement; (3) Garcia was deprived of due process because of the cumulative errors; (4) the district court abused its discretion in imposing a sentence that did not give proper weight and consideration to mitigating factors; and (5) the district court abused its discretion in ordering Garcia to pay restitution without adequately considering his current and future ability to pay restitution. Finding only that the district court abused its discretion in ordering restitution without proper consideration of Garcia's ability to repay the amount in the future, the Idaho Supreme Court affirmed conviction, vacated the restitution order, and remanded for reconsideration of Garcia's foreseeable ability to pay restitution. View "Idaho v. Garcia" on Justia Law

Joanie Smith was employed by the Glenns Ferry Highway District (the District) when she witnessed the District’s office manager overpaying herself on several occasions. Smith reported the overpayments to the District’s superintendent. Sometime after Smith reported these overpayments, the District terminated Smith’s employment. Smith filed suit, alleging adverse employment action in the form of discharge. At trial, the trial court ruled it would use the jury in an advisory capacity concerning any front pay damages. The jury returned a special verdict for Smith, awarding her both back pay and front pay. Following the jury’s verdict, the trial court rejected the jury’s verdict awarding front pay, and entered a reduced award. The trial court reasoned that: (1) the jury’s verdict with respect to front pay was advisory because front pay was an equitable remedy when awarded in lieu of reinstatement; (2) Smith had not properly pleaded “failure to promote” as an adverse action in addition to discharge; and (3) the jury had incorrectly used an erroneous full-time employment status in calculating front pay. The trial court also reduced Smith’s requested attorney fees to an amount less than she had contracted to pay. Smith unsuccessfully moved for post-judgment relief. Smith appealed, and the District cross-appealed, arguing that the issue of back pay also sounded in equity, and that the trial court should have reduced the jury award of back pay. After review, the Idaho Supreme Court determined the trial court erred: (1) when it ruled that there was no right to a jury trial on the issue of front pay; (2) by refusing to include the adverse action of “failure to hire” in the jury instructions and special verdict form; (3) by failing to instruct the jury on the “risk of uncertainty” to be borne by the District in its determination of damages; and (4) by denying Smith post-judgment interest. The Court determined the "failure to hire" instruction and "risk of uncertainty" errors were not prejudicial, and the jury award of front pay should have been reinstated. Smith’s request for entry of judgment nunc pro tunc was declined; however, on remand the trial court was asked to determine whether judgment nunc pro tunc should be entered as of the date of the jury’s verdict. Furthermore, the trial court abused its discretion in reducing the award of attorney fees from the amount Smith requested. The matter was remanded for further proceeedings. View "Smith v. Glenns Ferry Hwy Dist" on Justia Law

Prior to sentencing, defendant James Burke was committed to the state mental hospital for 56 days to restore him to competency. After being evaluated and deemed competent to proceed to trial, Burke was returned to the county jail and later pleaded guilty pursuant to a plea agreement. At the conclusion of his sentencing hearing, Burke sought credit for the 56 days of time spent in court-ordered commitment. The district court denied the motion, concluding that commitment to a state mental hospital did not fall under the definition of ‘incarceration’ in Idaho Code section 18-309. After reviewing this issue carefully, the Idaho Supreme Court disagreed with the district court’s "thorough and thoughtful analysis," holding that court-ordered commitment to state custody pursuant to Idaho Code sections 18-210 and 18-211 met the functional and legal definition of “incarceration” under Idaho Code section 18-309. "The extent of the liberty interests restricted by Burke’s court-ordered commitment to State Hospital North are just too similar to imprisonment to conclude otherwise." Accordingly, the Court reversed the district court’s order denying Burke’s request for credit for time served and remanded the case for the district court to enter an order crediting him with the fifty-six days he spent committed to State Hospital North while the State restored his competency to face criminal charges. View "Idaho v. Burke" on Justia Law

Sharon Walsh retained Swapp Law, PLLC, d/b/a Craig Swapp & Associates ("CS&A") after she was involved in two car accidents in 2013. In the negligence action stemming from the first accident, Walsh followed firm employee Stephen Redd’s advice and settled the case. Walsh then changed representation and, with her new counsel, settled the second case. On March 2, 2017, Walsh filed this action alleging, among other things, that CS&A was negligent in advising her to settle the first case while the second case was still pending and by failing to advise her of an underlying subrogation responsibility in the first case. CS&A moved for summary judgment. It argued that Walsh’s claim was time-barred under Idaho Code section 5-219(4)’s two-year statute of limitations because her malpractice claim began to accrue when she released the first claim. The district court agreed and granted the motion. Walsh timely appeals. Based on its review of the record, the Idaho Supreme Court determined the district court did not err in awarding summary judgment to CS&A. The district court properly determined that Walsh’s claim was time barred under Idaho Code section 5-219 because her cause of action accrued when she signed the release of claims for the First Collision case more than two years prior to her filing the action at hand. Further, the district court properly determined that the fraudulent-concealment provision of Idaho Code section 5-219(4) did not apply because Walsh was put on inquiry of CS&A’s alleged malpractice in June 2015, more than one year prior to filing this action. The district court’s decision granting CS&A’s motion for summary judgment and its final judgment were thus affirmed. View "Walsh v. Swapp Law" on Justia Law

Investor Recovery Fund, LLC was the assignee of six claims held by individual investors who lost their investments in the Hopkins Northwest Fund, LLC (the fund). Randall Hopkins and Brian Murphy were the principals of the fund, and together they owned and managed Hopkins Financial Services, Inc. (Hopkins Financial). The individual investors formed Investor Recovery for the purposes of asserting a collective claim against Hopkins Financial and the fund’s principals individually (collectively, Hopkins Associates). The fund declared a moratorium on redemptions in 2008, preventing investors from taking their money out of the fund. The individual investors lost their investments when the fund declared bankruptcy six years later. Investor Recovery sued Hopkins Associates, asserting claims of fraud by nondisclosure. The district court granted the principals’ motion for a directed verdict after seven days of trial, concluding that Investor Recovery did not prove that the individual investors’ losses were causally connected to the principals’ alleged nondisclosures. The Idaho Supreme Court addressed the applicable standard of review when considering a directed verdict in a fraud by nondisclosure case. Finding the district court used the wrong standard in entering directed verdict in favor of Hopkins Associates, the Supreme Court reversed the district court’s directed verdict, vacated the judgment, and remanded the case for further proceedings. View "Investor Recovery Fund v. Hopkins" on Justia Law

Nampa Highway District No. 1 (NHD) brought this action seeking to quiet title to a thirty-three-foot-wide strip of land constituting the south half of West Orchard Avenue in Canyon County, Idaho. NHD claimed that a 1941 deed conveyed the land to NHD. Appellants (defendants-below) argued that because the deed was not recorded until 1989, it did not affect their interests pursuant to the “Shelter Rule,” which protected a purchaser with notice if their predecessor in interest was an innocent purchaser. The district court granted summary judgment in NHD’s favor. After review, the Idaho Supreme Court reversed, finding the district court erred in granting summary judgment when there was a genuine issue of material fact as to what a reasonable investigation by Appellants' predecessors in interest would have revealed. The Supreme Court vacated the district court's declaration that NHD was the fee simple titleholder of the right-of-way, and the matter was remanded for further proceedings. View "Nampa Hwy Dist #1 v. Knight" on Justia Law

This case concerned an attempt by Jade Lee and Golden China, LLC, to appeal a magistrate court decision to the district court. The magistrate court awarded Brian Medrain dba Excellence Heating and Cooling (“Medrain”) damages in a breach of contract action against defendants Bing Lee, Jade Lee, and Golden China, LLC. Bing filed a timely pro se notice of appeal to the district court identifying all three defendants as the appellants; however, the notice of appeal was only signed by Bing as the appellant; neither Jade nor the attorney representing the defendants ever signed the notice of appeal. About ten months later the defendants retained new counsel who filed an amended notice of appeal on behalf of all three defendants. Medrain moved to dismiss the appeal. The district court granted Medrain’s motion in part and held that Jade and Golden China, LLC, did not timely appeal the magistrate court’s judgment. Finding no reversible error, the Idaho Supreme Court affirmed. View "Medrain v. Lee" on Justia Law