Justia Idaho Supreme Court Opinion Summaries

Natalie Shubert filed a negligence claim against her former public defender, Michael Lojek, former Ada County chief public defender Alan Trimming, and Ada County (collectively, “Ada County Defendants”). In 2008, Shubert was charged with two felonies and pleaded guilty to both charges. Her sentences were suspended in each case, and she was placed on probation. After a probation violation in 2011, the Ada County district court entered an order extending Shubert’s probation beyond the time period allowed by law, and the mistake was not caught. After Shubert’s probation should have ended in both cases, she was charged and incarcerated for a subsequent probation violation in 2014. Thereafter, in 2016, Shubert was charged with a new probation violation. Shubert was assigned a new public defender, who discovered the error that unlawfully kept Shubert on probation. Shubert’s new public defender filed a motion to correct the illegal sentence, raising the error that had improperly extended her probation. The district court granted Shubert’s motion to correct the illegal sentence and released Shubert from custody. Shubert then sued her original public defender, the Ada County Public Defender’s Officer, and other unknown Ada County employees alleging false imprisonment, intentional infliction of emotional distress, negligence per se, negligence, and state and federal constitutional violations. The district court dismissed all of Shubert’s claims except for negligence. In denying the Ada County Defendants’ motion for summary judgment on Shubert’s negligence claim, the district court held that public defenders were not entitled to common law quasi-judicial immunity from civil malpractice liability, and two provisions of the Idaho Tort Claims Act (ITCA) did not exempt public defenders from civil malpractice liability. The Ada County Defendants petitioned the Idaho Supreme Court, but the Supreme Court affirmed, finding the district court did not err in its finding that the public defenders and the County were not entitled to immunity. The case was remanded for further proceedings. View "Shubert v. Ada County" on Justia Law

Francisca Gomez died as the result of a horrific industrial accident that occurred while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed a district court’s grant of summary judgment to Crookham on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims fail as a matter of law because Crookham is not a “manufacturer.” The Idaho Supreme Court determined that given the totality of the evidence in this case, which included prior OSHA violations for similar safety issues, the district court erred by failing to consider whether Crookham consciously disregarded information suggesting a significant risk to its employees working at or under the picking tables, which were neither locked nor tagged out, as they existed on the date of the accident. On this basis, the decision of the district court granting summary judgment to Crookham was reversed and the matter remanded for the trial court to apply the proper standard for proving an act of unprovoked physical aggression, and to determine whether there was a genuine issue of material fact as to whether Crookham consciously disregarded knowledge of a serious risk to Mrs. Gomez. View "Gomez v. Crookham" on Justia Law

The State appealed a district court decision to grant defendant David Pool’s motion to suppress the results of a warrantless blood draw on the grounds that it was an unreasonable search under the Fourth Amendment to the U.S. Constitution. In 2016, a police officer came upon the scene of an automobile accident involving two vehicles, one of which was driven by Pool. Pool had failed to negotiate a turn and his vehicle was hit by oncoming traffic. He was not wearing a seatbelt and his airbag deployed in the crash. As a result, he sustained a head injury and was unconscious when the officer arrived at the scene. Pool’s son, a passenger in the vehicle, informed the officer that Pool had not been staying in his traffic lane prior to the crash. He also asserted that the doctors who had prescribed medication to Pool never told him that he could not drive while taking his medications. When Pool regained consciousness, the officer questioned him and noted that he appeared “very lethargic” and “had a presentation similar to a drunk driver . . . slurred speech and thick tongue and obviously disoriented.” Pool told the officer that he believed he had taken his prescription medications that day. Shortly thereafter, a large “baggy” containing seven bottles of prescription medication was recovered from Pool’s vehicle. The officer recognized several of the medications and suspected that they had caused Pool to be impaired. Around that time, Pool and his son were taken to the hospital. The officer followed to question Pool further. At the hospital, the officer ruled out alcohol as a cause of Pool’s impairment based upon the results of a horizontal gaze nystagmus test. The officer did not conduct other field sobriety tests, as he believed Pool’s medical condition rendered it improper for him to do so. Instead, he obtained a blood sample to be used for evidentiary testing. The issue this appeal presented for the Idaho Supreme Court's review centered on the officer’s justification for obtaining the blood sample without a warrant. The State maintained that pursuant to Idaho’s implied consent law, I.C. 18-8002(1), the search was reasonable and the district court erred in requiring proof of exigency. The Supreme Court concurred and reversed the district court. View "Idaho v. Pool" on Justia Law

Shane and Rebecca Ackerschott sued Mountain View Hospital, LLC, doing business as Redicare (“Redicare”), after Shane sustained an injury leading to paraplegia. A jury found Redicare’s treatment of Shane breached the standard of care and awarded the Ackerschotts $7,958,113.67 in total damages. After judgment was entered, Redicare filed a motion for judgment notwithstanding the verdict, or in the alternative, a new trial. The Ackerschotts also moved to alter or amend the judgment. All post-trial motions were denied. Redicare appealed, arguing the district court erred by not submitting an instruction on comparative negligence to the jury and by allowing testimony of the Ackerschotts’ expert witness. The Ackerschotts cross-appealed, arguing the cap on noneconomic damages imposed by Idaho Code section 6-1603 was unconstitutional. After review, the Idaho Supreme Court affirmed as to Redicare’s direct appeal, and declined to reach the merits of the Ackerschotts’ constitutional claim on cross-appeal. View "Ackerschott v. Mtn View Hospital; Redicare" on Justia Law

BrunoBuilt, Inc. appealed a district court’s dismissal of its claims against Strata, Inc., Chris Comstock, H. Robert Howard, and Michael Woodworth (collectively, “the Strata Defendants”). BrunoBuilt filed a professional negligence action against the Strata Defendants alleging that when the Strata Defendants rendered engineering services for the Terra Nativa Subdivision they failed to identify a pre-existing landslide and negligently failed to recommend construction of infrastructure that would stabilize and prevent further landslides within the Subdivision. A home BrunoBuilt had contracted to build and the lot on which the dwelling was located were allegedly damaged as a result. The district court dismissed BrunoBuilt’s claims after holding that the parties had entered into an enforceable settlement agreement, or alternatively, that summary judgment was warranted in favor of the Strata Defendants based on the economic loss rule. After review of the situation, the Idaho Supreme Court affirmed the district court judgment because the parties entered into an enforceable settlement agreement. View "Brunobuilt, Inc. v. Strata, Inc." on Justia Law

Shane Lee Dobbs appealed his conviction and the resulting sentence imposed after he pled guilty of lewd conduct with a minor under sixteen. On appeal, Dobbs contended the district court abused its discretion in fashioning a sentence based in part on a desire to “deter[ ] private vengeance” against him. Dobbs also contended his unified sentence of twenty-two years, with ten years fixed, was excessive in light of the mitigating factors. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed Dobbs’ judgment of conviction and sentence. View "Idaho v. Dobbs" on Justia Law

At issue before the Idaho Supreme Court in this case was a suit for medical malpractice brought by Leila Brauner against AHC of Boise, dba Aspen Transitional Rehab (Aspen). The claim arose out of Aspen’s delay in sending Brauner to the hospital following her knee replacement surgery, which was a substantial factor resulting in the amputation of Brauner’s right leg at the mid-thigh. After a trial, the jury entered a verdict in favor of Brauner and awarded her $2,265,204 in damages. Aspen appealed, alleging that various pre-trial and post-trial rulings were made in error and resulted in an unsustainable judgment. After review, the Supreme Court found no reversible error, and affirmed. View "Brauner v. AHC of Boise" on Justia Law

In an expedited appeal to the Idaho Supreme Court, a magistrate court terminated Jane Doe’s (“Mother”) parental rights after finding clear and convincing evidence that Mother neglected her children, K.M. and R.M., and that termination was in the best interests of the children. Mother did not appeal the magistrate’s finding that she neglected her children. She only appealed the magistrate court’s finding that termination was in the best interests of the children. The magistrate court found Mother’s testimony lacked credibility and relied on other witnesses to find that Mother had neglected her children under Idaho Code section 16-2005(1)(b) because Mother had failed to reunify with her children and had failed to comply with her case plan. According to Mother, termination was not in the best interests of her children because Mother had a close bond with her children, K.M. was not responding well to foster care, there was no evidence of violence between Mother and her children, and Mother tried to the best of her ability to comply with her case plan. The Supreme Court found substantial evidence supported the magistrate court's finding that termination was in the children's best interests, and affirmed. View "Idaho Dept. of Health & Welfare v. Jane Doe (2019-27)" on Justia Law

Primera Beef, LLC appealed a district court’s grant of summary judgment in favor of Allan Ward. Primera Beef alleged Ward breached the confidentiality provision of a settlement agreement between him and Primera Beef when Ward’s attorney disclosed the terms of the agreement to a prosecutor in a related criminal action. Ward moved for summary judgment, arguing that he was not liable for his attorney’s actions because his attorney was not acting within the scope of his authority when he disclosed the terms. The district court agreed. The Idaho Supreme Court concurred and affirmed the district court. View "Primera Beef v. Ward" on Justia Law

This appeal stems from a criminal defense attorney’s failure to adequately advise his client about the client’s constitutional rights against self-incrimination during a related civil deposition. Melvin Savage was convicted of first-degree arson and misdemeanor stalking. He filed a petition for post-conviction relief claiming that his trial counsel failed to adequately advise him about his rights under the Fifth Amendment of the U.S. Constitution and Article I Section 13 of the Idaho Constitution during a deposition in the civil case initiated by the victims of the arson. The district court granted the State’s motion for summary dismissal of the post-conviction petition. Savage then filed a pro se motion for relief from judgment under Idaho Rule of Civil Procedure 60(b) which was not considered. Savage then timely appealed the district court’s grant of summary dismissal and its order refusing to consider his Rule 60(b) motion. The Idaho Supreme Court determined the district court erred in summarily dismissing Savage’s petition for post-conviction relief because Savage raised a genuine issue of material fact regarding his counsel’s deficient performance. Therefore, the Court reversed the district court’s decision granting the State’s motion for summary dismissal. View "Savage v. Idaho" on Justia Law