Justia Idaho Supreme Court Opinion Summaries

Jakobe G. Martin was charged with three counts of statutory rape involving a 17-year-old female, K.F., who reported that Martin had raped her on three occasions. Martin allowed K.F., a runaway, to stay at his apartment, where she later accused him of both forced and consensual sexual intercourse. During the investigation, DNA evidence was collected, and K.F. made statements during a forensic interview that conflicted with the DNA results.The District Court of the Fourth Judicial District of Idaho heard the case. The State filed a motion in limine under Idaho Rule of Evidence 412 to exclude evidence of the victim’s sexual history. Martin argued that he should be allowed to use certain evidence for impeachment purposes, specifically to challenge a statement K.F. made during her forensic interview. The district court allowed Martin to inquire about the DNA results but barred the use of the victim’s statements about her sexual history for impeachment, citing Rule 412(b). Martin was convicted of one count of rape and sentenced to a twenty-year term, with seven years fixed and thirteen years indeterminate.The Supreme Court of Idaho reviewed the case. The court held that the evidence Martin sought to introduce was properly excluded under Rule 412(b), which prohibits evidence of an alleged victim’s past sexual behavior unless it falls within specific exceptions. The court also noted that Martin failed to provide the required notice under Rule 412(c). Consequently, the Supreme Court affirmed Martin’s judgment of conviction. View "State v. Martin" on Justia Law

Robert Nelson, a car salesman, sustained a back injury on March 29, 2018, while working for Dependable Auto Sales. He experienced significant back pain the following day, leading to a diagnosis of acute back pain with left radiculopathy. Nelson filed a worker’s compensation claim and underwent various treatments and evaluations. Medical opinions varied, with some attributing his back issues to preexisting conditions and obesity, while others recognized a work-related aggravation. Nelson also had a history of preexisting injuries, including knee surgeries and osteoarthritis.Nelson settled his worker’s compensation claim with his employer in September 2019 and subsequently filed a claim against the Idaho Industrial Special Indemnity Fund (ISIF) for total and permanent disability benefits. The Idaho Industrial Commission denied his claim, finding that Nelson failed to prove he was totally and permanently disabled or that he suffered a permanent impairment due to the work-related accident. The Commission’s decision was influenced by its determination that Nelson was not a credible witness, citing inconsistencies in his testimony and a prior conviction for insurance fraud.The Supreme Court of Idaho reviewed the case and affirmed the Commission’s decision. The Court found that substantial and competent evidence supported the Commission’s credibility determination, despite some errors in the Commission’s findings. The Court upheld the Commission’s conclusion that Nelson was not totally and permanently disabled, as the evidence indicated that there was still a labor market for him, even under the most restrictive limitations. The Court did not address the alternative finding regarding permanent impairment. View "Nelson v. State of Idaho, Industrial Special Indemnity Fund" on Justia Law

John Gomez, Gilbert Hurtado, and Jesus Hurtado were members of G&H Dairy, LLC, which defaulted on its loans in 2013. To avoid bankruptcy, they negotiated with Wells Fargo and signed a Letter of Intent (LOI) to distribute G&H's assets among themselves. Gomez and Jesus Hurtado purchased the personal property assets and assumed portions of G&H’s debt, but they could not agree on the sales price for the real property. Gomez sued the Hurtado brothers and G&H for breach of contract, estoppel, unjust enrichment, and breach of fiduciary duty, and sought judicial dissolution of G&H. The Hurtados counterclaimed for damages and also sought dissolution.The District Court of the Fifth Judicial District of Idaho granted summary judgment for the Hurtados on Gomez’s breach of contract claim, ruling the LOI unenforceable, but denied summary judgment on the other claims. After a bench trial, the court ordered the dissolution and winding up of G&H and dismissed the remaining claims. Gomez appealed.The Supreme Court of Idaho affirmed the district court’s decision. It held that the LOI was unenforceable as it was an offer contingent on future agreements and lacked definitive terms. The court also found no breach of fiduciary duty by the Hurtados, as the LOI was unenforceable and the parties had not agreed on the real property transfer terms. The court dismissed Gomez’s quasi-estoppel claim, concluding that the Hurtados did not change their legal position since the LOI was not enforceable. The court also upheld the district court’s final accounting and winding up of G&H, finding no error in the characterization of transactions or member allocations. The court awarded attorney fees to the Hurtados, determining that Gomez’s appeal was pursued unreasonably and without legal foundation. View "Gomez v. Hurtado" on Justia Law

Jessica Wiseman and her children sued Dr. Nathan Rencher and others for the wrongful death of Eric Wiseman, alleging medical malpractice and gross negligence. Rencher, the only defendant subject to Idaho's prelitigation screening panel requirement, moved for summary judgment, arguing that the Wisemans failed to comply with this requirement. He supported his motion with the panel’s advisory decision, filed under seal. The district court granted Rencher’s motion, concluding that the Wisemans did not meet the prelitigation requirement based on the advisory decision. The Wisemans also sought to disqualify the district judge, which was denied.The district court, part of the Seventh Judicial District of Idaho, ruled that the advisory decision could be considered to determine compliance with the prelitigation requirement. The court found the statutes ambiguous and concluded that they allowed limited review of the advisory decision. The court also ruled that the statutes controlled over conflicting Idaho Rules of Evidence. Consequently, the district court granted summary judgment in favor of Rencher, finding no genuine issue of material fact regarding the Wisemans' compliance with the prelitigation requirement.The Supreme Court of Idaho reversed the district court’s decision, holding that the prelitigation screening statutes unequivocally precluded judicial review of the advisory decision for any purpose. The court emphasized that the statutes clearly stated there should be no judicial review and that parties should not be affected by the panel’s conclusions. The Supreme Court remanded the case for further proceedings. Additionally, the court declined to disqualify the district judge on remand, distinguishing this case from precedent and finding no appearance of bias. Neither party was awarded attorney fees on appeal, as both prevailed in part. View "Wiseman v. Rencher" on Justia Law

Desiree Elaine Karst was a passenger in a car stopped by police in Kootenai County, Idaho. During the stop, a drug dog alerted to the presence of drugs, and Karst admitted to having drugs in the car. Additional drugs and paraphernalia were found on her at the jail. She was charged with multiple drug offenses and introducing contraband into a correctional facility. Karst moved to suppress the evidence, arguing the stop was impermissibly extended. The district court partially denied her motion, and Karst entered conditional guilty pleas, reserving her right to appeal. She was ordered to pay $569.50 in various court fees.Karst appealed the partial denial of her motion to suppress. The Idaho Supreme Court found the traffic stop was impermissibly extended, reversed the district court’s decision, and remanded the case. Subsequently, the prosecutor dismissed all charges against Karst. Karst then filed a motion to reimburse the fees she had paid, arguing that retaining her funds violated her due process rights. The district court denied her motion, citing a lack of jurisdiction and suggesting she sue each governmental entity that received the fees.The Idaho Supreme Court reviewed the case and held that the district court had both personal and subject matter jurisdiction to consider Karst’s motion for reimbursement. The court found that the State, by initiating the criminal case, had submitted to the district court’s jurisdiction. The court also determined that requiring Karst to file multiple civil suits to recover the fees would impose more than minimal procedures, violating her due process rights. The court reversed the district court’s decision and remanded the case for further proceedings, instructing that Karst should be reimbursed if she proves she paid the fees and her conviction was invalidated. View "State v. Karst" on Justia Law

The case involves a dispute between Brian L. Porter, trustee of the Brian L. Porter Revocable Trust, and Marvin A. Remmich, manager of McMillan Storage LLC, an Idaho limited liability company. The conflict centers on the management of the LLC and the conduct of its members. Remmich initially filed a complaint in California against Porter, alleging various breaches related to the construction of the LLC’s storage facility. Porter later filed a complaint in Idaho, accusing Remmich of mismanaging the LLC. Both parties reside in California, and the LLC’s principal place of business is also in California.In the California action, the court denied Porter’s motion to dismiss on grounds of forum non conveniens, retaining jurisdiction over the case. Subsequently, the Idaho District Court dismissed Porter’s claims without prejudice under Idaho Rule of Civil Procedure 12(b)(8), which allows for dismissal when another action between the same parties for the same cause is pending. The district court reasoned that the California court could adjudicate the entire controversy, and concurrent litigation would lead to increased costs and potentially inconsistent judgments.The Supreme Court of Idaho affirmed the district court’s decision. It held that the district court did not abuse its discretion in dismissing the Idaho action. The court found that the parties and claims in both actions were essentially the same, and the California court was in a position to resolve the entire dispute. The court emphasized considerations of judicial economy, minimizing litigation costs, and avoiding inconsistent judgments. Consequently, the Idaho action was dismissed without prejudice, and Porter was directed to pursue his claims in the California court. View "Porter v. Remmich" on Justia Law

The case involves a failed business relationship between Mike Jones, Jeremy Sligar, and Sligar's business, Overtime Garage, LLC. Jones claimed they formed a joint venture in 2011 to buy and sell used vehicles, which Sligar disputed. The relationship deteriorated, and Sligar terminated the venture in 2016. Jones filed a complaint in 2016 seeking a declaratory judgment, dissolution of the joint venture, and other relief. Sligar counterclaimed for similar relief. During the litigation, Safaris Unlimited, LLC, bought Jones's interest in the case at a sheriff's sale and settled the case by dismissing Jones's claims against Sligar.The District Court of the Fifth Judicial District, Twin Falls County, denied Jones's motion to set aside the judgment in the first case (Sligar I) and granted summary judgment to Sligar in the second case (Sligar II), finding that Jones's claims were barred by res judicata. The court also awarded attorney fees to Sligar and Safaris, finding Jones's motion to set aside the judgment was frivolous and untimely. Jones appealed these decisions, arguing the consolidation of small claims actions with Sligar I was improper and that his Rule 60(b) motion was timely.The Supreme Court of Idaho affirmed the district court's decisions. It held that the consolidation of the small claims actions with Sligar I was proper, as the small claims were related to the disputed property in Sligar I. The court also found that Jones did not file his Rule 60(b) motion within a reasonable time, as he delayed over five months without a valid reason. Additionally, the court upheld the summary judgment in Sligar II, agreeing that Jones's claims were barred by res judicata. The court awarded attorney fees to Sligar for the appeal in Sligar I but not in Sligar II, as Sligar did not prevail on its cross-appeal. View "Jones v. Sligar" on Justia Law

In 1988, Rodney Araiza was involved in a riot at the Idaho State Penitentiary, during which an inmate named Richard Holmes was murdered. Araiza was charged with first-degree murder and participating in the riot. At trial, the State presented evidence, including testimonies and Araiza’s bloody palm prints, suggesting Araiza's involvement in the murder. Araiza defended himself by claiming he arrived at Holmes' cell after the murder. Despite his defense, Araiza was convicted by a jury on both charges in 1989.After his conviction, Araiza filed a motion for a new trial, presenting new evidence, including a confession from another inmate, Merle LaMere, who claimed responsibility for the murder. However, the district court denied the motion, finding the new evidence unlikely to result in an acquittal. Araiza was sentenced to life imprisonment for murder and 20 years for riot, to be served concurrently. Araiza's subsequent appeals, including a direct appeal, were unsuccessful.In 2019, Araiza filed a petition for post-conviction relief, claiming actual innocence and requesting DNA and fingerprint testing. The district court dismissed the petition, stating that the DNA evidence would not likely prove Araiza's innocence and that his claims were barred by res judicata. Araiza did not receive notice of this dismissal until after the appeal period had expired. He then filed a motion for relief from judgment under Idaho Rules of Civil Procedure 60(b)(1) and 60(b)(6), which led to the district court reentering judgment.Araiza appealed the reentered judgment, but the Idaho Court of Appeals dismissed the appeal as untimely. The Supreme Court of Idaho reviewed the case and concluded that Araiza's appeal was indeed untimely, as his motion for relief from judgment was filed outside the six-month limit for Rule 60(b)(1) motions. Consequently, the Supreme Court dismissed Araiza’s appeal for lack of jurisdiction. View "Araiza v. State" on Justia Law

In 2018, Brian Hollis pleaded guilty to one count of lewd conduct with a minor under sixteen and four counts of sexual exploitation of a child. He also admitted to being a repeat sexual offender, which mandates a fifteen-year minimum term of confinement. The district court imposed an indeterminate life sentence with twenty-five years determinate on the lewd conduct charge and concurrent determinate sentences of fifteen years for each of the sexual exploitation charges. Hollis appealed his conviction and sentence, but the Idaho Court of Appeals affirmed them.Hollis then filed a pro se petition for post-conviction relief, alleging ineffective assistance of trial counsel. The district court appointed the Kootenai County Public Defender to represent him. However, Hollis' conflict counsel filed a motion to withdraw, stating that he was no longer able to "ethically or effectively represent" Hollis due to statements made by the district court judge against conflict counsel in a similar post-conviction case. The district court denied the motion to withdraw and the motion to continue the summary disposition hearing. The district court subsequently granted the State’s motion for summary disposition, holding that Hollis had not supported any of his claims with any admissible evidence.The Supreme Court of the State of Idaho vacated the judgment of the district court, reversed the decisions on the motion to continue and motion to withdraw, vacated the decision granting summary disposition to the State, and remanded for further proceedings. The court held that the district court abused its discretion in denying the motion to withdraw and the motion to continue. The court also ordered the assignment of a new district court judge on remand. View "Hollis v. State" on Justia Law

The case revolves around Thomas E. Hennig, Jr., who was discharged from his job at Money Metals Exchange, L.L.C. after making a controversial comment on the company's instant messaging system. Hennig referred to himself as his employer’s “good little Nazi” in a joke about enforcing the company’s time clock rules. After his termination, Hennig applied for unemployment benefits, but his application was denied by the Idaho Department of Labor (IDOL) on the grounds that he was discharged for misconduct connected with his employment. Hennig appealed this decision to the Idaho Industrial Commission, which upheld the IDOL's decision.Hennig then appealed to the Supreme Court of the State of Idaho, arguing that the Commission’s decision was unsupported by competent and substantial evidence. He contended that his use of the term "Nazi" was not objectively unprofessional and that the company had tolerated racist remarks from another employee. The Supreme Court of Idaho reversed the Commission’s decision and remanded the case for further proceedings. The court found that the Commission had failed to properly analyze whether the company's expectations of Hennig's behavior were objectively reasonable, given evidence that it had tolerated racist comments from another co-worker and then promoted him to a supervisory position. The court also found that the Commission had failed to consider Hennig's claim that the company had encouraged his unorthodox humor. View "Hennig v. Money Metals Exchange" on Justia Law