Justia Idaho Supreme Court Opinion Summaries

The Department of Environmental Quality (“DEQ”) brought a civil enforcement action under the Environmental Protection and Health Act against David Gibson and VHS Properties, LLC, (“VHS”), for illegally operating a composting facility. After a three-day bench trial, the district court determined that Gibson was operating a “Tier II Solid Waste Processing Facility” without prior approval from DEQ. The district court assessed a civil penalty and issued an injunction. On appeal, Gibson raised a number of issues regarding DEQ’s authority to regulate compost and its inspection of the property. DEQ argued Gibson’s appeal was partially time-barred. After review, the Idaho Supreme Court held that although Gibson’s appeal was not time-barred, he failed to show error. Therefore, it affirmed the district court. View "DEQ v. Gibson" on Justia Law

Penny Phillips, her son, and daughter, brought a medical malpractice suit against various Idaho Falls health care providers. Phillips and her children alleged the health care providers were negligent in the care they provided to Phillips’ husband, Scott Phillips, immediately prior to his death by suicide. The district court rejected the Phillipses’ claims by granting summary judgment in favor of the health care providers. The Phillipses appealed several adverse rulings by the district court. The health care providers cross-appealed, contending the district court abused its discretion in amending the scheduling order to allow the Phillipses to name a rebuttal expert. The Idaho Supreme Court determined summary judgment was improvidently granted: it was an abuse of the trial court's discretion in: (1) granting the providers' motion for a protective order preventing the Phillipses from conducting a I.R.C.P. 30(b)(6) deposition regarding the community standard of care; (2) in allowing depositions of local familiarization experts because it did not apply the correct standard; and (3) striking an expert's testimony because that expert demonstrated the requisite actual knowledge of the local standard of care. The court did not abuse its discretion in granting the Phillipses' motion to amend the scheduling order. Therefore, the trial court's judgment was reversed and the matter remanded for further proceedings. View "Phillips v. Eastern ID Health Svcs" on Justia Law

Thomas Hooley appealed a district court’s decision to dismiss his pro se filing entitled “Motion For New Trial Based on Evidence withheld in violation of Brady with attached exhibits in support of motion.” In July 2014, a jury convicted Hooley of first-degree kidnapping and aiding and abetting aggravated battery. Hooley unsuccessfully appealed his conviction to the Court of Appeals. The Idaho Supreme Court denied his petition for review and issued a remittitur on December 18, 2015. In May 2018, Hooley lodged a pro se filing with the district court. Almost 200 pages in length, the first pages of the filing were a “sparse” legal template on which Hooley handwrote information. In the substantive portion of the motion, Hooley wrote that a “New Trial motion based on evidence withheld in violation of Brady cannot be denied on basis that new trial would not have produced different outcome and such violations not subject to harmless error analysis.” He also included statements of law and citations. The district court treated the filing as an untimely motion for a new trial based on newly discovered evidence under Idaho Criminal Rule 34. The district court denied the motion as untimely, reasoning that Hooley’s motion was filed outside of the 2-year time constraint on Rule 34 motions because his underlying judgment of conviction became final on December 18, 2015, when the remittitur was issued. Hooley appealed and argued that the district court should have construed his filing as a petition for post-conviction relief. The Court of Appeals affirmed. After granting Hooley’s timely petition for review, the Idaho Supreme Court concurred with the district court and affirmed its order. View "Idaho v. Hooley" on Justia Law

Jeff Good and Harry’s Dairy entered into a contract providing that Harry’s Dairy would purchase 3,000 tons of Good’s hay. Harry’s Dairy paid for and hauled approximately 1,000 tons of hay over a period of approximately eight weeks, but did not always pay for the hay before hauling it and at one point went several weeks without hauling hay. After Harry’s Dairy went a month without hauling additional hay, Good demanded that Harry’s Dairy begin paying for and hauling the remaining hay. Harry’s Dairy responded that it had encountered mold in some of the hay, but would be willing to pay for and haul non-moldy hay at the contract price. Good then sold the remaining hay for a substantially lower price than he would have received under the contract, and filed a complaint against Harry’s Dairy alleging breach of contract. Harry’s Dairy counterclaimed for violation of implied and express warranties and breach of contract. The district court granted summary judgment in favor of Good on all claims, and a jury ultimately awarded Good $144,000 in damages. Harry’s Dairy appealed, arguing that there were several genuine issues of material fact precluding summary judgment, that the jury verdict was not supported by substantial and competent evidence, and that the district court erred in awarding attorney fees, costs, and prejudgment interest to Good. The Idaho Supreme Court determined the district court erred only in its decision with respect to Good’s breach of contract claim and Harry’s Dairy’s breach of the implied warranty of merchantability claims. Judgment was vacated and the matter remanded for further proceedings. View "Good v. Harry's Dairy" on Justia Law

The Board of County Commissioners for Bonner County, Idaho (“Board”) granted Stejer’s, Inc.’s request for three variances (“the Variances”) from applicable lot setbacks required by the Bonner County Revised Code. Neighboring land owners, Frank Hungate and Thomas Hungate, as trustees of the Hungate Trust, the A&E Family L.L.C., Anne Ashburn, Eleanor Jones, Frank Hungate, and John Hungate (collectively “the Hungates”) appealed the Board’s decision. The district court held that the Board erred in approving the Variances, but ultimately affirmed the Board’s decision after it determined that the Hungates failed to show that their substantial rights were prejudiced. The Hungates appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Hungate v. Bonner County" on Justia Law

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