Justia Idaho Supreme Court Opinion Summaries

At issue before the Idaho Supreme Court in this matter centered on whether a person bringing a tort claim against a governmental entity for alleged child abuse had to comply with the notice requirement of the Idaho Tort Claims Act. Seven individuals (collectively, the Juveniles) filed suit alleging they had been abused while they were minors in the custody of the Idaho Department of Juvenile Corrections. In its ruling on summary judgment, the district court found the Juveniles’ claims based on Idaho Code section 6-1701 were not barred by the notice requirements of the Idaho Tort Claims Act. The Idaho Department of Juvenile Corrections and its employees moved for permission to appeal, which was granted, and they argued the district court erred by allowing the Juveniles’ claims to proceed. The Idaho Supreme Court held that because of the plain language of the ITCA, the notice requirement applied to claims based on tort actions in child abuse cases. Accordingly, the Court reversed the district court’s decision and remanded the case for further proceedings. View "D.A.F. v. Lieteau and Juvenile Corrections Nampa" on Justia Law

On the evening of June 17, 2018, Appellants Shane Dodge and his wife Christine (“the Dodges”) were returning home with their son after having dinner together, when they turned onto District Two Road and saw a police car partially blocking their lane of travel. At that time, two Bonners Ferry police officers, Sergeant William Cowell and Officer Brandon Blackmore, were conducting a traffic stop of another vehicle. To avoid hitting them, Shane drove slowly by the two cars, and then pulled over about four car-lengths away. He exited his car and approached the police officers. He informed them that the location “was a pretty stupid place to pull people over.” Sergeant Cowell instructed Shane that he could be arrested for obstruction or interfering with the traffic stop, whereupon Shane said, “go to hell.” Shane was then arrested and placed in the back of the patrol car. When she saw her husband being arrested, Christine exited her car and attempted to approach and question the officers. When she asked the officers why they were arresting her husband, Sergeant Cowell told Officer Blackmore to arrest her too, but Officer Blackmore ordered her to leave the scene. Shane was taken to the county jail and booked. Thereafter, he posted bond and was released. The Dodges appealed after a district court dismissed their tort claim against the Bonners Ferry Police Department, Sergeant Cowell and Officer Blackmore. The grounds for dismissal was failing to file a notice of tort claim pursuant to Idaho Code sections 6-610 et seq., and for failing to post a bond prior to commencing their cause of action. Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Dodge v. Bonners Ferry Police Department" on Justia Law

The Idaho Board of Licensure of Professional Engineers and Professional Land Surveyors (the Board), through its executive director, Keith Simila, brought disciplinary proceedings against Chad Erickson for allegedly violating certain statutes and rules governing the surveying profession. Following an administrative hearing, the Board found that Erickson violated a number of the statutes and rules alleged and revoked his license as a professional land surveyor. Erickson sought judicial review by the district court. On review, the district court upheld the Board’s finding that Erickson had committed certain violations; however, the district court reversed the portion of the Board’s Order revoking Erickson’s license and remanded the matter for further consideration of the appropriate sanction. Erickson appeals from the district court’s decision, arguing that the evidence does not support the Board’s finding of any violations. In addition, Erickson asserts that numerous procedural errors made by the Board necessitate reversal. After its review, the Idaho Supreme Court reversed the district court's order, finding the Board's order against Erickson was time-barred. View "Erickson v. Idaho Board of Licensure of Professional Engineers & Professional Land Surveyors" on Justia Law

This case involved a question regarding the proper amount of credit for time served to which Christopher Osborn was entitled under Idaho Code section 19-2603, the statute governing rearrest for a probation violation. Osborn violated a no contact order twice, pleaded guilty to the misdemeanor charges, and was given consecutive sentences of 365 days in jail on each count. Both sentences were suspended and he was placed on probation for two years on each count to be served concurrently. He was later arrested for, and admitted to, violating the terms of his probation; he served 106 days in jail from the date of his arrest before admitting the violations. The magistrate court granted Osborn 106 days credit for time served against the first of his consecutive sentences. Osborn then filed a Rule 35 motion seeking credit for time served against both consecutive sentences. The magistrate court denied Osborn’s motion. Osborn appealed to the district court, and it reversed the magistrate court’s denial and granted Osborn credit for time served against both sentences. The State appealed, but finding no error in the district court’s calculation, the Idaho Supreme Court affirmed. View "Idaho v. Osborn" on Justia Law

Eldon Samuel III appealed after a jury found him guilty of second degree murder for killing his father and first degree murder for killing his brother. Samuel’s younger brother was severely autistic and required significant attention. Both of Samuel’s parents had prescription drug addictions which led to financial problems, criminal charges, and arrests. Throughout Samuel’s childhood the family lived in shoddy, cockroach-infested residences and moved frequently, usually after they had been evicted for not paying rent. Samuel’s mother started abusing pain pills following a car accident when Samuel was 4, became suicidal, and was hospitalized several times. Samuel’s father became addicted to pain pills after he injured his shoulder at work. Samuel’s father began to believe that a “zombie apocalypse” was inevitable. Samuel’s mother testified that Samuel’s father taught him how to kill zombies by playing violent video games, watching zombie themed movies, and training Samuel to use knives and guns. In 2014, officers responded to a 911 call at the Samuel residence that the father had been shot. Samuel would give officers a different version of events that night. Samuel’s father was on medication when he shot a .45 gun outside, believing that a “zombie apocalypse” had begun. Samuel told his father to go back inside. Once his father went inside he pushed Samuel in the chest and told him to leave. Samuel picked up his father’s gun, and when his father pushed him a second time, Samuel shot him in the stomach. Samuel’s father then crawled to Samuel’s brother’s room, leaving a trail of blood on the floor. Samuel did not believe the first shot killed his father and shot him three more times in the head once he reached Samuel’s brother’s room. Samuel got a shotgun and shot his brother while he was under the bed. Samuel reloaded the shotgun and continued to shoot his brother. Samuel then dropped the shotgun and started to stab at his brother with a knife. Samuel moved the mattress off of the bed frame and got a machete. Samuel swung the machete at his brother through the gaps in the wood planks of the bed frame. When his brother tried to climb out from underneath the bed, Samuel hit him in the back of the head with the machete. Samuel continued to swing the machete as hard as he could until his brother stopped talking and was quiet. At that point, Samuel called 911. Originally, the State charged Samuel with two counts of first degree murder. However, after a preliminary hearing, the magistrate court found the State had not established probable cause on the premeditation element for the murder of Samuel’s father. Thus, Samuel was charged with first degree murder for his brother and second degree murder for his father. Samuel challenged the district court’s refusal to suppress certain statements he made to police. He also challenged the sufficiency of the evidence presented against him at trial. Finding these challenges unpersuasive, the Idaho Supreme Court affirmed conviction. View "Idaho v. Samuel" on Justia Law

This appeal came from a district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” Picatti contended Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers (I.C. § 18-705), and aggravated battery on law enforcement. Ultimately, Picatti was convicted, accepting a plea agreement to disturbing the peace and failure to obey a traffic sign. Two years later, Picatti brought his 42 U.S.C. 1983 suit, claiming he was deprived of his rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the deputies, holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. The Idaho Supreme Court affirmed summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

Rebecca Parkinson appealed a district court’s dismissal of her claim for breach of fiduciary duty against her attorney, James Bevis. Parkinson filed a complaint alleging Bevis breached his fiduciary duty when he disclosed a confidential email to the opposing attorney after reaching a settlement in Parkinson’s divorce action. Bevis moved to dismiss under Idaho Rule of Civil Procedure 12(b)(6), arguing that Parkinson’s complaint failed to state a claim for relief. The district court agreed and dismissed Parkinson’s claim after determining that it was, in essence, a legal malpractice claim, on which Parkinson could not prevail because she admitted that she suffered no damages from Bevis’ disclosure. The Idaho Supreme Court determined the district court erred in dismissing Parkinson's complaint: whether an attorney must forfeit any or all fees for a breach of fiduciary duty to a client must be determined by applying the rule as stated in section 37 of the Restatement (Third) of the Law Governing Lawyers and the factors the Supreme Court identified to the individual circumstances of each case. In light of this conclusion, the district court’s determination that Parkinson could not pursue her claim on an equitable basis as a matter of law was incorrect. The matter was remanded for further proceedings. View "Parkinson v. Bevis" 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 vacated the child custody judgment, finding the magistrate court abused its discretion in allowing Brandon's hired expert's opinion on parenting time. "The use of parenting time evaluations is unique to custody disputes;" the authority for and parameters guiding the use of such evaluations were governed by court rule IRFLP 719. "These evaluators are performing a 'judicial function,' entitling them to quasi-judicial immunity, because of the important, impartial work they perform as an extension of the court. ... The importance of an evaluator’s neutrality cannot be overemphasized." The Court affirmed certain evidentiary rulings and remanded for further proceedings. View "Kelly v. Kelly" on Justia Law

Due to a failed breath alcohol test and multiple convictions for driving under the influence, the Idaho Transportation Department permanently suspended Bruce Edwards’ driving privileges to operate a commercial motor vehicle. The district court affirmed the Department’s order and Edwards appealed. After review of the Department’s order and the circumstances leading to the suspension, the Idaho Supreme Court affirm the district court’s judgment and the Department’s lifetime disqualification of Edwards’ commercial motor vehicle driving privileges. View "Edwards v. Transportation Dept" on Justia Law

Four appeals arose from a consolidated subcase that was a part of the broader Coeur d’Alene-Spokane River Basin Adjudication (CSRBA). The United States Department of the Interior (the United States), as trustee for the Coeur d’Alene Tribe (the Tribe), filed 353 claims in Idaho state court seeking judicial recognition of federal reserved water rights to fulfill the purposes of the Coeur d’Alene Tribe’s Reservation (the Reservation). The Tribe joined the litigation. The State of Idaho (the State) and others objected to claims asserted by the United States and the Tribe. The district court bifurcated the proceedings to decide only the entitlement to water at this stage, with the quantification stage to follow. After cross-motions for summary judgment, the district court allowed certain claims to proceed and disallowed others. The district court specifically allowed reserved water rights for agriculture, fishing and hunting, and domestic purposes. The district court allowed reserved water rights for instream flows within the Reservation, but disallowed those for instream flows outside the Reservation. The district court determined priority dates for the various claims it found should proceed to quantification, holding generally the Tribe was entitled to a date-of-reservation priority date for the claims for consumptive uses, and a time immemorial priority date for nonconsumptive uses. However, in regard to lands homesteaded on the Reservation by non-Indians that had since been reacquired by the Tribe, the district court ruled the Tribe was entitled to a priority date of a perfected state water right, or if none had been perfected or it had been lost due to nonuse, the Tribe’s priority date would be the date-of-reacquisition. The Idaho Supreme Court affirmed in part and reversed in part. The Supreme Court determined the district court improperly applied the controlling case law's rule of "primary-secondary" distinction and instead should have allowed aboriginal purposes of plant gathering and cultural uses under the homeland purpose theory. Furthermore, the Court determined the priority date associated with nonconsumptive water rights was time immemorial. The Court affirmed the remainder of the district court’s decisions and remanded for further proceedings. View "United States v. Idaho" on Justia Law