Justia Idaho Supreme Court Opinion Summaries

Dave Christensen was indicted by a grand jury on five counts of lewd conduct with two minors under sixteen. The State notified Christensen of its intent to introduce interviews of the two alleged victims at trial under Idaho Rules of Evidence (“I.R.E.”) 803(4) and 803(24). At a pretrial hearing, the district court ruled the interviews were admissible because the victims’ statements were made for purposes of medical diagnosis or treatment. The interviews were admitted at trial by stipulation. A jury found Christensen guilty on four of the five counts. Christensen appealed the district court’s admission of the interviews. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Christensen" on Justia Law

This appeal stemmed from a dispute between neighbors over the validity of an easement. In 1997, the Fitzpatricks bought two adjacent lots. In 2016, while they still owned both lots, they recorded an easement that granted the owners of the first lot (themselves) the right to maintain, repair, and improve a portion of the second lot. They then sold the second lot to the Kents. Two years later, the Kents allegedly made certain modifications to the easement area that the Fitzpatricks opposed. The Fitzpatricks claimed that the easement precluded the Kents from making the modifications, but the Kents asserted that the easement was unenforceable. The Fitzpatricks and Kents filed cross-complaints in district court, each seeking to quiet title to the easement area. The district court granted the Kents’ motion for summary judgment after concluding that the easement was invalid under the merger doctrine. The district court granted costs to the Kents but denied them attorney fees under Idaho Code section 12-121. The Fitzpatricks appealed the district court’s summary judgment decision and the Kents cross-appealed the district court’s denial of their request for attorney fees. Finding no reversible error, the Idaho Supreme Court affirmed the district court's decisions. View "Fitzpatrick v. Kent" on Justia Law

Jeffrey Marsalis appealed a district court’s decision summarily dismissing his petition for post-conviction relief from his 2009 rape conviction. Marsalis alleged that his trial counsel was ineffective for failing to: (1) challenge the testimony of the State’s expert witness regarding his and the victim’s blood alcohol levels; (2) present favorable eyewitness testimony at trial; and (3) properly advise him of his speedy trial rights under the Interstate Agreement on Detainers (IAD). After review, the Idaho Supreme Court reversed in part, and affirmed in part the district court's decision. The Court affirmed the district court’s summary dismissal of Marsalis’s claim that trial counsel was ineffective for failing to call an allegedly favorable eyewitness at trial. However, it reversed and remanded the case for an evidentiary hearing on Marsalis’s claim that trial counsel was ineffective for failing to challenge the underlying methodologies supporting the State’s expert witness’s testimony and for failing to present an expert witness to discuss the scientific basis behind Marsalis’s blackout defense. The Court also remanded the case back to the district court so it could provide Marsalis with twenty days’ notice to respond to the court’s grounds for dismissing Marsalis’s claim that trial counsel was ineffective for failing to inform him of his speedy trial rights under the IAD. View "Marsalis v. Idaho" on Justia Law

Glen Ward appealed an order and final judgment of the district court granting the State’s motion for summary dismissal and dismissing his petition for post-conviction relief. In 2014, Ward was convicted of sexual abuse of a minor under 16 years of age after he pleaded guilty to all elements of the crime except for the sexual intent element, to which he entered an Alford plea. He was sentenced to 18 years imprisonment with a 7-year fixed term. Ward asked for, and was granted, appointment of counsel to represent him in the post-conviction relief proceedings. After granting the motion, the district court appointed a conflict public defender to represent Ward in the action. Although he had secured new counsel, Ward subsequently filed numerous pro se documents. Ward argued the district court abused its discretion by denying his motion to proceed pro se as moot. Ward also argued the district court erred in denying his motion to proceed pro se because a post-conviction petitioner has a right to proceed pro se. After review, the Idaho Supreme Court vacated in part and affirmed. The Court held that the district court should have refused to entertain Ward’s independent filings in the first place; to the extent that the district court entertained the filings made by Ward as opposed to by his attorney, it was error to do so. However, having come to the conclusion that the district court erred, not by ruling incorrectly on Ward’s purported motion, but by ruling on it at all, the Supreme Court did not need to reverse the district court’s separate order and final judgment granting summary dismissal. "Because we hold that there was no motion properly before the district court to be ruled upon in the first place, the district court’s denial of the purported motion has no impact on the propriety of its final decision and judgment dismissing Ward’s post-conviction petition on the merits." View "Ward v. Idaho" on Justia Law

Michelle Ryerson appealed district court decisions entered during the dissolution and winding up of West Foothills TIC, a partnership in which she was a partner. Specifically, Ryerson argued the district court misapplied the Idaho Uniform Partnership Act by entering an order requiring liquidation of the partnership’s real property by sale at a fixed price, and by allowing her former partner the opportunity to purchase the property from the partnership. Ryerson also argued the district court erred in granting summary judgment on the issue of the real property’s value as of the date of dissolution because, as the real property’s owner, she was presumed competent to testify about its value. Finally, Ryerson argued the district court erred in dismissing her counterclaim seeking a determination that she was entitled to 50 percent of the partnership’s profits upon dissolution. Joseph Guenther, the other partner in West Foothills TIC, cross-appealed, arguing the district court misapplied a provision of the Idaho Uniform Partnership Act by determining that it could not allow Guenther to purchase the partnership’s real property without the consent of the partnership’s creditors. Guenther also argued the district court erred in declining to award him attorney’s fees because he was the prevailing party and the gravamen of his claims was a commercial transaction. After review, the Idaho Supreme Court reversed and remanded, holding: (1) the Idaho Uniform Partnership Act required the sale of partnership property upon dissolution unless otherwise agreed by the parties; and (2) the district court erred in fixing the price at which the property was to be listed for sale. The Court reversed the district court’s order attributing 100 percent of post-dissolution increases in equity in the partnership’s real property to Guenther. The Court affirmed the district court’s order denying attorney’s fees. View "Guenther v. Ryerson" on Justia Law

Phillip and Marcia Eldridge filed a medical malpractice suit against Dr. Gregory West (West), Lance Turpin, PA-C (Turpin), and Summit Orthopaedics Specialists, PLLC (Summit), alleging Phillip became infected with Methicillin-Resistant Staphylococcus Aureus (MRSA) as a result of malpractice committed by West, Turpin, and agents of Summit. West performed hip replacement surgery on Phillip’s right hip in October 2009. In 2012, West performed what he later described as exploratory surgery on Phillip’s hip to determine the source of Phillip’s pain, as well as the potential replacement of components if an infection were found. All of the test results from the samples sent to the pathology department indicated there was no infection in the hip. Rather than explant the hip in its entirety, West replaced only the metal ball at the head of the femur with a ceramic ball. Following the second surgery, Phillip experienced numerous adverse complications. Phillip would have another revision a few months later, during which the MRSA was discovered. The Eldridges claimed West and Turpin breached the standard of care that was due them and as a result, sustained damages. The district court granted various motions, including a motion to dismiss certain causes of action against West, Turpin, and Summit, as well as a motion for summary judgment brought by Turpin and Summit, and a motion for partial summary judgment brought by West. In their appeal, the Eldridges contended the district court erred by: (1) dismissing their claims for negligent and intentional infliction of emotional distress, gross negligence, and reckless, willful, and wanton conduct; (2) denying their motion to strike the affidavits of West and Turpin; (3) limiting their claim for damages; and (4) concluding that the Eldridges could only present evidence of damages, specifically medical bills, after the Medicare write-offs had been calculated. In affirming in part and reversing in part, the Idaho Supreme Court concluded the district court erred in refusing to strike portions of West’s first affidavit and Turpin’s affidavit because they were conclusory. Furthermore, the district court abused its discretion in precluding the Eldridges from putting on proof of damages that arose after April 24, 2013, and their presentation of damages. Orders granting summary judgment to West regarding the Eldridges’ informed consent claim and Turpin were affirmed. The matter was remanded for further proceedings. View "Eldridge v. West" on Justia Law

Siranoush Hiatt appealed an Idaho Industrial Commission decision that affirmed the Idaho Department of Labor’s denial of her request for unemployment benefits. The Commission determined that Hiatt was ineligible for benefits because she was terminated from Health Care Idaho Credit Union (“HCICU”) for workplace-related misconduct. After review, the Idaho Supreme Court affirmed based on the substantial evidence in the record which supported the Commission’s decision. View "Hiatt v. Health Care ID Credit Union" on Justia Law

Bennett Day, Trustee of Trust B of the Donald M. and Marjorie D. Day Family Trust, John Day, Dan E. Day, Holcomb Road Holdings, LLC, Donna Day Jacobs, and David R. Day (collectively, the Day family) appealed a district court's decision dismissing their claims against the State of Idaho and the Idaho Transportation Department (the Department). This case related to certain property the Day family owned near Isaacs Canyon in Ada County, Idaho. In the 1990s, the State began working on the Isaacs Canyon Interchange near the Day property. The frontage road (Eisenman Road) was extended to the interchange. Eisenman Road did not reach the Day property. In late 1997, which the parties each stipulated was the date for valuation of any taking, the Department substantially completed construction of the Isaacs Canyon Interchange project. After the interchange was completed, the State transferred jurisdiction and maintenance of Eisenman Road southwest of the Interchange to the Ada County Highway District (ACHD). In 2014, the Department applied to ACHD to obtain access from Eisenman Road to the Day property. In 2015, the Department offered the Day family $560,000 to build an access road themselves, but the Days rejected the offer. In May 2016, ACHD advised the Department that it would “not accept a public street” needed to create the access desired by the Day family. Following ACHD’s denial of the Department’s application, the Day family filed this action, asserting claims against the Department for inverse condemnation, breach of contract, and breach of the implied covenant of good faith and fair dealing. Both parties moved for partial summary judgment and the Department moved to dismiss the Day family’s complaint. The Day family appealed when the district ocurt dismissed its claims. Their appeal presented for the Idaho Supreme Court's review: (1) a question of whether the district court erred by considering the Department’s motion to dismiss without notifying the Day family that it would consider matters outside of the pleadings; (2) a question of whether the district court correctly dismissed the Day family’s claims for lack of standing and for untimeliness; and (3) whether either party was entitled to an award of attorney fees on appeal. The Supreme Court determined the district court: erred in granting summary judgment for the Department on all of the Day family’s inverse condemnation claims; erred by granting summary judgment on the contract claim; and incorrectly held that the statute of limitations barred the inverse condemnation claims of Donna Day Jacobs and David R. Day. Furthermore, the Court determined the district court erred by dismissing the Day family’s contract-based claims. View "Day v. Idaho Transportation Dept" on Justia Law

In 2011, a district court granted Aaron Roth a temporary furlough while he was in jail for a probation violation. Under the furlough order, Roth was released from custody. Roth failed to return. In 2017, six years after he absconded, Roth was arrested and later charged with escape, a felony under Idaho Code section 18-2505. A jury found Roth guilty of escape. Roth then moved the district court for a judgment of acquittal under Idaho Criminal Rule (“I.C.R.”) 29, or in the alternative, to dismiss pursuant to I.C.R. 48(a)(2). The district court granted the motion to dismiss under I.C.R. 48(a)(2). The State appealed the district court’s dismissal. After review, the Idaho Supreme Court concluded the district court abused its discretion by dismissing Roth's case. "This ruling extended the reach of due process too far. ... Due process is not a rigid standard and is satisfied when a defendant is provided notice and an opportunity to be heard. Roth had his opportunity to be heard and was sufficiently notified of the furlough order’s requirements to satisfy due process based on the district court explaining the details of the furlough order on the record at the arraignment hearing. The fact, as found by the district court, that Roth did not receive a written copy of the furlough order does not vitiate the notice that Roth had received in court from the judge." The Supreme Court reversed dismissal and remanded for further proceedings. View "Idaho v. Roth" on Justia Law

Amey Nelson brought a negligence claim against Stefani Kaufman, the Idaho Falls Anytime Fitness, and AT Fitness, LLC. Nelson was using a weight machine at the Idaho Falls Anytime Fitness under the direction of Kaufman, a personal trainer, when Nelson injured a metacarpal bone in her hand. Nelson filed suit alleging that Kaufman had improperly instructed her on the machine’s use, which caused her injury. The district court granted summary judgment in favor of Kaufman, holding that Kaufman was an express or apparent agent of Anytime Fitness and therefore released from liability under the terms of the Member Assumption of Risk and Release form Nelson signed when she joined the gym. Nelson unsuccessfully moved for reconsideration, and appealed. The Idaho Supreme Court determined Nelson did not waive her appeal by failing to expressly challenge the district court's finding of an express agency relationship. The Court determined the district court erred in granting summary judgment to Kaufman on the basis that Kaufman was an express agent of Anytime Fitness. Further, the court erred in apply the apparent agency doctrine defensively to find Kaufman was covered by the specific terms of the Membership Agreement. With judgment reversed, the Supreme Court remanded the case back to the district court for further proceedings. View "Nelson v. Kaufman" on Justia Law