Justia Idaho Supreme Court Opinion Summaries

Eagle Creek Irrigation Company (“Eagle Creek”) appealed a district court's grant of summary judgment in favor of A.C. & C.E. Investments, Inc. The dispute centered on 15 shares of Eagle Creek stock which authorized the holder to divert 30 cfs of water (or 15 miner’s inches) of Eagle Creek’s water right. AC&CE Investments purchased 15 acres (“the Property”) located within Eagle Creek’s boundaries. The prior property owners also owned 15 shares in Eagle Creek stock. The question presented on appeal was whether the 15 shares passed as an appurtenance to the Property. The district court ruled that AC&CE Investments acquired 15 shares in Eagle Creek when it acquired title to the Property because the shares passed as an appurtenance to the Property. Eagle Creek appealed. The Idaho Supreme Court determined the district court erred in granting summary judgment to AC&CE Investments because the district court did not look to Eagle Creek’s governing documents. The Supreme Court therefore vacated the portion of the district court’s final judgment which stated that the 15 shares of the Eagle Creek stock were appurtenant to the Property. View "Eagle Creek Irrigation v. A.C & C.E Investments" on Justia Law

Chad Schiermeier was convicted by jury of grand theft. DARE/PAL was a non-profit organized “to foster, promote, encourage and increase the knowledge, and understanding of alcohol and drug addictions or related problems.” To further its purpose, DARE/PAL offered outdoor-related group activities during the summer months to children between the ages of nine and sixteen. Some of the activities included hiking, golfing, fishing, rafting, and attending baseball games. The activities were primarily funded by the Blaine County Idaho Sheriff’s Office through drug forfeiture funds and by local philanthropists through donations and grants. Schiermeier was a deputy sheriff for the Blaine County Sheriff’s Office from 1999 to 2015, serving as a middle school resource officer and the director of DARE/PAL; he was appointed as manager of the program in 2002. Following Schiermeier’s appointment as manager, the board slowly became inactive, neglecting its duties and entrusting Schiermeier to handle all things related to DARE/PAL. In July 2015, a charitable group called 100 Men Who Care donated approximately $5,100 to DARE/PAL. Shortly thereafter, the group followed up with Schiermeier’s supervisor, Lieutenant Carpita, to see how their donation had been spent. Carpita in turn asked Schiermeier. Several months went by with vague responses, if any, from Schiermeier. Finally, in November 2015, after more than three months of requests and meetings, Schiermeier provided Carpita with the requested DARE/PAL bank records. After reviewing the records, Carpita became suspicious after he noticed “a lot of cash withdrawals through the ATM . . . during times when the PAL activities were not going on.” Consequently, Carpita decided to have the matter independently investigated by the Idaho State Police. The bank records revealed that from 2009 to 2015, Schiermeier made several extravagant purchases of high-end outdoor equipment and clothing. Following the independent investigation by the Idaho State Police, the State charged Schiermeier with one count of grand theft. Schiermeier appealed his judgment of conviction, arguing the State did not prove the elements of grand theft beyond a reasonable doubt. Schiermeier also argued the district court abused its discretion by imposing an excessive sentence. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Schiermeier" on Justia Law

SSI Food Services Inc. (SSI) appealed the district court’s decision rejecting the Board of Tax Appeal’s (BTA) 2016 assessed value of SSI’s food processing facility in favor of the Canyon County Assessor’s (Canyon County) significantly higher valuation. On appeal, SSI argued the district court erred when it modified the BTA’s valuation because: (1) Canyon County did not meet its burden of proving that the BTA’s valuation was erroneous; (2) the modified valuation was not supported by substantial and competent evidence; and (3) the conclusions of law contained in the district court’s findings of fact and conclusions of law are inadequate. SSI also appealed the district court’s decision to allow Canyon County’s expert to testify on rebuttal. Canyon County cross-appealed the district court’s decision that SSI was not obligated to pay penalties and interest on the unpaid amount of property taxes. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed the district court. View "Stender v. SSI Food Services, Inc." on Justia Law

Defendant-appellant Tom Katsilometes challenged the Idaho Senate’s order granting over $18,000 in attorney fees to Senator W. Marcus Nye, awarded after Nye prevailed against Katsilometes in a contest over the results of the 2016 general election. The Senate confirmed Nye’s election and awarded him costs and attorney fees. Because Katsilometes refused to pay the attorney fees, Nye brought an action in district court seeking a declaratory judgment ordering Katsilometes to pay him the amount ordered by the Senate. The district court granted the declaratory judgment and further awarded Nye costs, attorney fees, and prejudgment interest. The Idaho Supreme Court determined the Senate did not have the authority to award attorney fees to Nye at the time of the election contest. Nye was not entitled to recover his litigation costs, attorney fees, and prejudgment interest in the district court action. Therefore, the Idaho Supreme Court reversed the district court’s order enforcing the award of attorney fees to Nye pursuant to the order of the Idaho Senate, and vacated all costs, attorney fees, and prejudgment interest awarded to Nye by the district court. Neither side was entitled to attorney fees on appeal; however, as the prevailing party, Katsilometes was entitled to his costs on appeal. View "Nye v. Katsilometes" on Justia Law

Aaron Lantis was charged with the misdemeanor offense of disturbing the peace in violation of Idaho Code section 18-6409. The State alleged he committed the crime by sending sexually suggestive photographs of H.H. (Lantis’ ex-girlfriend) to her employer in an unsuccessful attempt to have her fired During trial, Lantis moved for a judgment of acquittal asserting that the statute did not apply to his actions. The magistrate court denied Lantis’ motion. Lantis was found guilty by a jury and he made the same motion post-verdict, which was likewise denied. He appealed to the district court, asserting the same grounds. The district court agreed with Lantis and vacated Lantis’ conviction, holding that Lantis’ conduct was outside the scope of the statute. The State appealed; the Idaho Supreme Court affirmed the district court. View "Idaho v. Lantis" on Justia Law

In 2009, a jury convicted Vance Thumm of aggravated battery or aiding and abetting aggravated battery and of being a persistent violator of the law. Thumm pursued a direct appeal, but was unsuccessful. In 2013, through counsel, Thumm petitioned for post-conviction relief. The State responded by filing a motion for summary disposition. The district court eventually granted the State’s motion and dismissed the post-conviction petition. Thumm appealed to the Idaho Supreme Court, alleging: (1) ineffective assistance of counsel at trial, sentencing, and on appeal; (2) a Brady violation; (3) prosecutorial misconduct; and (4) cumulative error. Finding no reversible error, the Supreme Court affirmed the district court’s grant of summary disposition. View "Thumm v. Idaho" on Justia Law

This case arose from the division of a three-member accounting firm, Siddoway, Wadsworth & Reese, PLLC. The three members of the firm were the personal professional corporations solely owned by each accountant. In early 2015, Reese PC signed a purchase agreement to buy a one-half interest in the client base of Siddoway PC for $200,000. This purchase agreement included an arbitration clause. In August of 2015, Siddoway left the accounting firm, taking several employees and the clients’ information with him. Following Siddoway’s departure, the firm (now named Wadsworth Reese, PLLC), along with its remaining members, filed a complaint in the district court against Siddoway and his personal professional corporation and two of the employees who followed him. Siddoway counterclaimed. The parties brought a range of claims. Reese PC and Siddoway PC also went to arbitration for claims related to their purchase agreement, but the arbitrator determined the purchase agreement was void for failure of a condition subsequent. The remaining claims between the parties were tried by the district court. The district court ultimately decided to “leave the parties where it found them.” This included final determinations pertinent to this appeal: (1) dissociation of Siddoway’s personal professional corporation as a firm member; (2) Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration; (3) Siddoway PC failed to show unjust enrichment from the void purchase agreement; and (4) the firm could fund Reese’s personal professional corporation’s litigation and arbitration costs because resolving the purchase-agreement dispute served a legitimate business purpose. Siddoway and Siddoway PC appealed. The Idaho Supreme Court affirmed the district court’s judgment: Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration, nor did they show unjust enrichment or breach of membership duties. View "Wadsworth Reese v. Siddoway & Co" on Justia Law

Mario Ayala was injured while driving a company truck in 2009, and was injured again in 2013 after falling from a ladder. After the hearing, but before the referee issued “recommended findings and determination” in accordance with Idaho Code section 72-717, the Industrial Commission reassigned the case to itself over Ayala’s objection. Citing the referee’s backlog of cases and a need for efficiency, the Industrial Commission issued an order finding that Ayala’s low-back condition was not causally related to his 2009 truck wreck, that he was not totally and permanently disabled under the odd-lot worker doctrine, and that he suffered disability of 40% of the whole person inclusive of impairment of his 2009 and 2013 industrial accidents. The Idaho Supreme Court set aside the Commission’s findings of fact, conclusions of law and order because Ayala was denied due process when the Industrial Commission reviewed Ayala’s claims and issued a decision without the referee’s recommended findings and determination. The Court also set aside the Industrial Commission’s post-hearing order on motion for reconsideration and order on motion for reconsideration, modification and consolidation, and remanded this matter for a new hearing. View "Ayala v. Meyers Farms" on Justia Law

The State appealed a district court order granting Monica Wolfe’s motion to suppress evidence obtained from a cell phone in her possession.In early 2017, a dog owned by Robert Wolfe and his new wife became unusually lethargic and eventually died. Around that same time, they noticed golf balls in their yard, some of which had been chewed. Because no one in the family played golf and they did not live near a golf course, suspicion arose. As a result, the family initiated an investigation through Animal Control and discovered that the golf balls appeared to have antifreeze residue on them. A veterinarian later confirmed that the dog died due to ingesting antifreeze and golf balls. From this, the family suspected that the dog had been poisoned. Soon after the dog died, Daniel Collins, a man who had dated Robert’s ex-wife, defendant Monica Wolfe, contacted Robert and informed him that he had been solicited by Wolfe to kill Robert and his dog. Robert met with Collins at a restaurant and, unbeknownst to Collins, recorded their conversation. During the conversation, Collins stated that Wolfe asked him to find out when Robert left work so that he could “take [him] out from there.” Regarding the dog, Collins said that he was hoping he could “get to [Robert]” before it died, and that Wolfe’s plan was to mix car antifreeze with meatballs to kill the dog. He further asserted that Wolfe “was asking [him] for help . . . but basically wanted to be the one to have [Robert] underground” because “she [was] angry” with him for obtaining custody of their two kids. After this conversation, Robert contacted the police to report Wolfe and Collins. Wolfe was later interviewed. She also admitted to having a conversation about killing a neighbor’s dog with antifreeze, but denied killing Robert’s dog. Further, she and the detective discussed text messages that were on a cell phone in her possession. The district court held that law enforcement unlawfully seized the phone prior to obtaining a warrant to search it. The State argued the "independent source exception" applied because law enforcement subsequently obtained a valid search warrant that was not tainted by the unlawful seizure, and therefore, the evidence found on the phone should not have been suppressed. The Idaho Supreme Court disagreed and affirmed the district court. View "Idaho v. Wolfe" on Justia Law

Christopher Shanahan appealed a district court decision denying his motion to correct an allegedly illegal sentence imposed in 1997. In the Fall of 1995, Shanahan and two friends devised a scheme to rob a convenience store in Grant, Idaho, and use the money to travel to Las Vegas, Nevada. Once there, they planned to join a gang and lead a life of crime. Shanahan argued his indeterminate life sentence, with the first thirty-five years fixed, for the murder he committed as a juvenile in 1995 was equivalent to a life sentence without the possibility of parole. Therefore, he argued that under Miller v. Alabama, 567 U.S. 460 (2012) and persuasive precedent from other states, he was entitled to a new sentencing where his youth and its attendant characteristics could be properly considered. Otherwise, he argued, his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The district court denied the motion on the basis that Miller was inapplicable to Shanahan’s sentence and, even if it applied, the sentencing court heard testimony regarding his age and mental health prior to sentencing him. Finding no reversible error, the Idaho Supreme Court affirmed Shanahan's conviction. View "Idaho v. Shanahan" on Justia Law