Justia Idaho Supreme Court Opinion Summaries

This appeal arose from a contractual dispute between the Christopher W. James Trust (“the Trust”) and Idaho Mineral Springs, LLC, a water bottling company owned by Helmut Tacke. In 2000, Tacke built Idaho Mineral Springs’ bottling facility on approximately 10 acres of a 374 acre parcel he owned in Lemhi County, Idaho. He installed a high-density polyester pipeline running about eight-tenths of a mile from a spring on the property to the water-bottling plant. From 2000 to 2013, Tacke sold little to no bottled water. By March 2013, Tacke owed on two promissory notes secured by mortgages on the property. That same year, Tacke’s machinery malfunctioned and he needed to obtain new equipment. Tacke negotiated an agreement with Christopher James (“James”), who, with his wife, Debra, were trustees of the Trust and the Firstfruits Foundation (“Firstfruits”), a 501(c)(3) nonprofit foundation. The Agreement called for Firstfruits to pay off the outstanding loans on the property. In exchange, Tacke transferred title to 364 acres of the property, retaining the 10 acres of land where Idaho Mineral Springs’ operations were conducted. The Agreement further provided that the Trust would loan Idaho Mineral Springs $500,000 for two years with a 5% interest rate. Because James expected that the U.S. dollar would depreciate against the Australian dollar and precious metals, the Agreement called for the loan to be repaid in specified quantities of gold, silver and Australian dollars (“the commodity basket”). The Agreement also called for quarterly interest payments of 1.25% based upon the value of the commodity basket. Firstfruits entered into a joint venture with another nonprofit, Youth Employment Program, which sought to develop and manage the 364 acres. A conflict arose between the parties over Tacke’s waterline: Adams removed Tacke’s mainline and replaced it with a new PVC system. Adams reduced the flow to Idaho Mineral Springs from 91 gallons per minute (a discharge rate that Adams believed “could collapse the mainline”) to 30 gallons per minute. Tacke claimed that the new water system prohibited a direct flow of water from the spring to his plant and operated at a dramatically lower pressure than Tacke needed for Idaho Mineral Springs’ operations. Tacke appealed the district court’s ultimate judgment in favor of the Trust for $653,793.40. The Idaho Supreme Court reversed and remanded, finding that the awards of contract damages and prejudgment interest had to be vacated because the Trust failed to prove the value of the commodity basket. The matter was remanded for further proceedings. View "Christopher W. James Trust v. Tacke" on Justia Law

Petitioner Sherri Ybarra, the Idaho Superintendent of Public Instruction, petitioned the Idaho Supreme Court for a declaratory judgment, writ of mandamus, or writ of prohibition to remedy various alleged constitutional violations by the Idaho Legislature and the Idaho State Board of Education related to the funding and supervision of eighteen employees currently working in the Idaho Department of Education. During the 2020 legislative session, the Idaho Legislature passed two appropriation bills - Senate Bills 1409 and 1410 - which transferred supervision of eighteen full-time job positions within the Department’s Technology Group to the Board along with approximately $2.7 million in funding for those positions. The Superintendent argues that “by splitting eighteen employees away from three other workers and eliminating all funding for the office space, rent, and the maintenance and upgrading of the Department’s computers, this line item appropriation decentralizes and damages operations.” She also claimed these bills were the Legislature’s attempt to “strip the Superintendent of her authority through the budget process,” in retaliation for her failure to support a 2019 revised school funding formula. To effectuate such relief, the Superintendent invoked the Supreme Court's original jurisdiction, seeking a declaratory judgment that the Appropriation Bills were unconstitutional. The Superintendent sought a writ of mandamus and/or prohibition that would allow SB 1409's funding appropriation to the Board remain intact, but would restore the Superintendent's full management authority over the Technology Group. The Supreme Court found the Appropriations Bills constitutional, thereby declining to address requests for writs of mandamus and/or prohibition. View "Ybarra v. Legislature of the State of Idaho" on Justia Law

Travelers Insurance Co. appealed a district court decision to affirm a final order of the Idaho Department of Insurance in favor of Ultimate Logistics, LLC (“Ultimate”). The Department of Insurance’s final order upheld a hearing officer’s determination that two mechanics working for Ultimate were improperly included in a premium-rate calculation made by Travelers. In its petition for review, Travelers argued the Department of Insurance acted outside the scope of its statutory authority in determining that the mechanics could not be included in the premium-rate calculation. The district court rejected this argument. Finding no reversible error in the district court's order, the Idaho Supreme Court affirmed. View "Travelers Insurance v. Ultimate Logistics, LLC" on Justia Law

Quentin Nava appealed after he was convicted on one count of lewd and lascivious conduct and one count of sex abuse. The charges arose from an approximately two-day period in July 2016 when Nava was staying in the home of a female friend, her twelve-year-old daughter, her twelve-year-old niece, as well as other friends and relatives who were staying at the woman’s house. He argued that the district court erred when it denied his motion to sever the two counts. Nava argued the similarities between the two counts did not constitute a common scheme or plan as to justify joinder of the two charges. The Idaho Court of Appeals agreed, and vacated Nava’s judgment of conviction. The State petitioned for review, and finding no reversible error in the appellate court's judgment, the Idaho Supreme Court affirmed. View "Idaho v. Nava" on Justia Law

Max Pease failed to stop his vehicle before rear-ending Brent Weddle’s vehicle. The force of the collision caused Weddle’s vehicle to cross over into oncoming traffic and collide with a pickup truck owned by Mabel Robin Blackeagle. Dana McCandless was the driver of the pickup truck and Blackeagle was a passenger. A jury found Pease and Weddle negligent and awarded damages as a result. Dissatisfied with the amount of the verdict, McCandless and Blackeagle moved for a new trial on the comparative negligence and damages, and argued there were errors at trial to warrant a new one. The district court granted their motion in part and ordered a new trial unless Pease agreed to an additur of $4,000. Pease accepted the additur. McCandless and Blackeagle appealed the district court’s order on their motion for a new trial. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s order. View "McCandless v. Pease" on Justia Law

Clinton Haggard appealed a district court’s decision to affirm a magistrate court’s judgment of conviction. After a trial, the magistrate court found Haggard guilty of misdemeanor domestic battery in violation of Idaho Code section 18-918(3)(b). The issue presented for the Idaho Supreme Court's review was whether aggard effectively waived his right to a jury trial. The Court found Haggard’s waiver was ineffective because the magistrate court did not, in open court, inquire into whether the waiver was knowing, intelligent, and voluntary. The Court therefore reversed the district court’s decision and remanded this case with instructions to the district court to remand this case to the magistrate court with instructions to vacate the judgment of conviction. View "Idaho v. Haggard" on Justia Law

John Rodriguez sold a firearm to an individual who had visible gang tattoos and had previously identified himself as a member of the Norteno gang, but who was actually an informant paid by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The State charged Rodriguez with two counts of providing firearms to criminal gang members under Idaho Code section 18-8505 and a sentencing enhancement for providing the firearm to further criminal gang purposes under Idaho Code section 18-8503(1)(b). After trial, the jury returned a verdict of guilty as to Count I but not guilty as to Count II and answered "no" to the sentencing enhancement question. The district court suspended a unified sentence of ten years and placed Rodriguez on probation for ten years. Rodriguez appealed, arguing his conviction should have been vacated because criminalizing the sale or transfer of firearms to gang members without the intent to further gang activity, Idaho Code section 18-8505 violated rights guaranteed by the federal Constitution: the freedom of association under the First Amendment, the right to bear arms under the Second Amendment, and the due process requirement of personal guilt under the Fourteenth Amendment. Finding that Rodriguez forfeited his constitutional challenges by failing to present them to the trial court, the Idaho Supreme Court affirmed. View "Idaho v. Rodriguez" on Justia Law

Over a period of several months, William Dix bought several thousand dollars’ worth of goods from Grainger Supply on credit. On the same days he bought the goods, he pawned them. Dix was charged with grand theft and burglary, and pleaded not guilty to both counts. At trial, the State argued that Dix committed theft by obtaining the goods on credit without intending to pay for them, and committed burglary by receiving loans from the pawn shop in exchange for the goods based on false representations that he owned them. After the close of the State’s case-in-chief, Dix moved for a judgment of acquittal under Idaho Criminal Rule 29 on both charges, arguing that under Idaho v. Bennett, 246 P.3d 387 (2010), he became the owner of the goods once he obtained possession of them from Grainger, and as the owner, he could lawfully pawn them. The district court denied Dix’s motion, and the jury subsequently returned guilty verdicts on both counts. After trial, Dix renewed his Rule 29 motion on the burglary charge, and this motion was also denied. The district court entered an order withholding judgment and placing Dix on probation for eight years. Dix timely appealed, and the Court of Appeals affirmed. Upon certiorari review, the Idaho Supreme Court reversed Dix’s convictions and remanded the case to the district court with instructions to enter a judgment of acquittal on both counts. View "Idaho v. Dix" on Justia Law

In a divorce action between Lexi and Robert Ellis, the magistrate court granted Ms. Ellis’ motion for appointment of a receiver, subject to the express condition that the costs of the receiver would be paid from community funds. The district court affirmed a series of decisions made by the magistrate court relating to Bruce Denney’s efforts to collect payment for services he performed as a receiver and forensic accountant in the Ellis divorce. After the divorce was final, Denney’s accounting firm, Poston, Denney & Killpack, PLLC (“PDK”) moved to intervene to recover payment from Robert Ellis, which the magistrate court granted. Later, the magistrate court granted PDK’s motion for summary judgment and ordered Mr. Ellis to pay one-half of Mr. Denney’s fees. The magistrate court declined to rule on the reasonableness of the fees at that time, determining further proceedings would be necessary. PDK filed a motion for a determination of the reasonableness of fees. After a hearing the magistrate court granted PDK’s motion and held Mr. Denney’s fees were reasonable. The magistrate court also awarded attorney fees to PDK in bringing the action to recover attorney fees. Mr. Ellis appealed to the district court, which upheld the magistrate court’s decision and also awarded attorney fees to PDK on appeal. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Ellis v. Ellis" on Justia Law

Steven Chambers appealed his conviction entered upon his "Alford" plea to battery with intent to commit a serious felony. Chambers was initially charged with forcible rape against a young woman. Pursuant to I.R.E. 412, Chambers moved to introduce evidence of a purportedly false allegation "N.S." made against a different individual approximately six months after her alleged rape by Chambers. The State objected to the admission of such evidence. After a Rule 412 hearing, the district court excluded evidence of the purportedly false allegation. The Idaho Court of Appeals heard Chambers’ appeal and held that false allegations made after the charged conduct could be admissible. However, the appellate court concluded that Chambers had failed to prove falsity at the Rule 412 hearing. After its review, the Idaho Supreme Court concluded the district court erred when it determined that Rule 412 contained a temporal requirement that the false allegation must precede the events giving rise to the charge. Further, the district court abused its discretion by applying the wrong balancing test. The Supreme Court announced guidelines and procedure for the district court to use on remand to determine whether evidence of the purportedly false allegation was admissible. Judgment of conviction was vacated and the matter remanded for further proceedings. View "Idaho v. Chambers" on Justia Law