Justia Idaho Supreme Court Opinion Summaries

After a dispute over a fence project, the Eagle Springs Homeowner’s Association (“HOA”) filed a complaint seeking injunctive relief against Jan Rodina, a homeowner in the HOA. Rodina asserted, among other defenses, that the HOA approved his project and waived the right to enforce certain provisions of the subdivision’s Covenants, Conditions, and Restrictions (“CC&Rs”). The district court awarded summary judgment in favor of the HOA and granted injunctive relief. After review, the Idaho Supreme Court affirmed, finding that the HOA did not approve his project as built and that Rodina failed to show that a genuine issue of material fact precluded the award of summary judgment against him. View "Eagle Springs HOA v. Rodina" on Justia Law

Three cases were consolidated by the Idaho Supreme Court for the purposes of appeal. The cases involved three separate actions: one brought by First Security Corporation and two others brought by Richard Fosbury to quiet title to their purported ownership of irrigation water rights to land owned by Belle Ranch, LLC. All parties agreed that partial decrees for the water rights were issued in the Snake River Basin Adjudication (SRBA) in the name of South County Estates, LLC. As South County’s successors in interest, First Security and Fosbury argued their interests in the water rights are senior and therefore superior to the interest of Belle Ranch, LLC. Notwithstanding these claims, the district court quieted title to the water rights in question to Belle Ranch, LLC. First Security and Fosbury appeal. The Idaho Supreme Court determined First Security and Fosbury’s claims were precluded by res judicata: the claims were the same claims that were adjudicated in the SRBA. The Supreme Court found it was appropriate for the district court to quiet title in favor of Belle Ranch, LLC, because Belle Ranch, LLC, filed a notice of a change in ownership during the pendency of the SRBA. Accordingly, the Court affirmed the district court’s judgment. View "First Security v. Belle Ranch" on Justia Law

Dale Johnson maintained roller coasters for Silverwood, Inc. Among rising contentions and a dispute with Silverwood’s new director of construction and maintenance, Johnson resigned his position on June 8, 2015. He subsequently applied for unemployment benefits, but his claim was denied. Johnson challenged the denial with the Appeals Bureau of the Idaho Department of Labor, and a hearing was held on August 5, 2015. When denied again, Johnson appealed to the Industrial Commission. While the appeal was pending, Johnson learned that his hearing’s recording was lost. The Industrial Commission remanded the case to the Appeals Bureau for a new hearing. Ultimately, after two additional hearings and a second appeal to the Industrial Commission, Johnson won his claim for benefits with the Commission finding that Johnson was eligible for benefits. Johnson subsequently filed suit against the Department of Labor for unnecessary delays and other alleged improprieties in the handling of his claim. The district court dismissed the case for failure to file a notice of tort claim pursuant to the Idaho Tort Claims Act and then denied Johnson’s post-judgment motions. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed the district court. View "Johnson v. Idaho Dept of Labor" on Justia Law

Brandi and Brandon Kelly were married and had a son. After about two years of marriage Brandon filed for divorce. Once the divorce was final the magistrate court awarded sole legal custody and primary physical custody of the child to Brandon. Brandi filed a permissive appeal, arguing the magistrate court erred by relying on an inadmissible parenting time evaluation and following the recommendations of a biased evaluator. The Idaho Supreme Court determined the magistrate court abused its discretion by permitting Brandon to hire Dr. Jane McNaught to perform a parenting time evaluation as his expert. "[M]ost of the errors stem from the magistrate court's reliance on Brandon's experts," and the court specifically declined to appoint Dr. McNaught as the court's expert under IRFLP 719. "Parenting time evaluators must adhere strictly to the ethical principles that govern their conduct as a neutral." The Supreme Court determined the facts of this case established how the court’s appointment of Dr. McNaught violated these legal standards. While there was some evidence in the record to support the magistrate court’s custody decision, that evidence was so tainted by the court’s reliance on Dr. McNaught’s testimony, the Supreme Court found it was unreliable. In addition, the magistrate court abused its discretion in ordering Brandi to undergo psychological evaluation and counseling as recommended by Dr. McNaught. The Supreme Court affirmed certain evidentiary rulings for guidance upon remand, but it did vacate the custody judgment and remanded for a new trial. View "Kelly v. Kelly" on Justia Law

Jacob Davis appealed a district court’s denial of his motion for a new trial. Following his convictions in two separate cases, and subsequent appeals, Davis moved for a new trial in both cases based on two grounds: (1) the verdicts were contrary to the law or the evidence; and (2) newly discovered evidence. Under the newly discovered evidence claim, Davis claimed the State failed to preserve exculpatory evidence on Facebook, thereby allowing the evidence to be destroyed. The district court denied both motions. On appeal to the Idaho Supreme Court, Davis argued the district court abused its discretion by not applying the proper standard to his newly discovered evidence claim, and that application of the proper standard would have yielded the opposite result. Davis further argued that as a result of this abuse of discretion, his right to a fair trial was violated. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Davis" on Justia Law

The named plaintiff, Mike Zeyen sought declaratory relief and recovery of damages from Pocatello/Chubbuck School District No. 25 on behalf of all students currently enrolled in the district and their guardians. Zeyen alleged that School District 25’s practice of charging fees violated Article IX, section 1, of the Idaho Constitution. Zeyen first sought to certify the class to include all students within School District 25. Zeyen’s later motion to amend sought to add a takings claim under both the Idaho and U.S. Constitutions. The district court denied Zeyen’s motion for class certification based on lack of standing and denied his motion to amend both as untimely and prejudicial to School District 25. The Idaho Supreme Court determined Zeyen failed to show that the district court abused its discretion by denying his second motion for leave to amend the complaint. Furthermore, the Court determined Zeyen lacked standing to bring his class action suit. The Court therefore affirmed the district court's denial of Zeyen's motion to certify the class and denial of his motion for leave to amend the first amended complaint. View "Zeyen v. Pocatello/Chubbuck School Dist 25" on Justia Law

Plaintiff Jackie Raymond alleged, among other things, that Idaho State Police (“ISP”), Payette County, and Deputy Sloan (collectively “defendants”) tortiously interfered with a prospective civil action. The defendants moved for dismissal of this claim, arguing Idaho did not recognize the tort, and even if it did, Raymond lacked standing and her claims were too speculative to establish causation. The district court agreed with defendants, holding that: (1) Idaho had not recognized the tort as an independent cause of action; (2) it would not acknowledge the tort; and (3) the facts were too speculative to establish such a claim. Raymond appealed and requested the Idaho Supreme Court to formally adopt a new tort for intentional interference with a prospective civil action by spoliation of evidence by a third party. The Supreme Court found that Idaho courts already recognized the cause of action, but took the opportunity to state this conclusion explicitly. The Court therefore reversed. View "Raymond v. Idaho State Police" on Justia Law

Gilbert Gonzales, Jr., appealed the district court’s order denying his motion to suppress evidence obtained following a warrantless seizure. Gonzales was arrested and charged with possession of methamphetamine and introducing or attempting to introduce methamphetamine into a correctional facility. Gonzales moved to suppress, asserting the warrantless seizure was without legal justification and the evidence obtained was fruit of that illegality. The district court denied the motion after finding the seizure was lawful. The Court of Appeals reversed the district court’s order denying the motion to suppress. The Idaho Supreme Court granted the State’s petition for review and reversed the district court’s order denying Gonzales’ motion to suppress and vacate the judgment of conviction. The Supreme Court determined, based on a review of the record, police lacked a reasonable, articulable suspicion to seize Gonzales. View "Idaho v. Gonzales, Jr." on Justia Law

Jesse Keeton appealed a district court’s order denying him credit for time served. In 2018, Keeton was in custody for thirty-two days following his arrest for driving under the influence of alcohol. The district court dismissed the case without prejudice because the State made a charging error. A few weeks later, the State refiled the case, charging Keeton with the same offense but under a different case number. After Keeton was sentenced, he requested credit for time served. The district court denied his request because Keeton did not have a sentence imposed in the dismissed case and he was not incarcerated before judgment was entered in the refiled case. On appeal, Keeton argued Idaho Code section 18-309, the credit for time served statute, mandated an award of credit when a case involving the same offense was dismissed and later refiled. The Idaho Supreme Court agreed and reversed the district court. View "Idaho v. Keeton" on Justia Law

Upon belief Coleton Sessions was selling tainted marijuana that had caused adverse medical symptoms to its users, police officers arrived at and entered Sessions’ house, and seized illegal substances and paraphernalia. Sessions was arrested and charged with multiple criminal offenses. He moved to suppress the evidence seized by the officers because it was procured without a warrant in violation of his constitutional rights. Based on the information that the officers had at the time they entered the home, the district court determined it was not reasonable for officers to believe that anyone inside the home was in need of immediate medical assistance and granted Sessions’ motion to suppress. The State appealed, arguing the warrantless entry and search were justified because of exigent circumstances. The Idaho Supreme Court determined that because the district court’s conclusions were supported by substantial and competent evidence, it affirmed the district court’s order granting the motion to suppress. View "Idaho v. Sessions" on Justia Law