Justia Idaho Supreme Court Opinion Summaries

John Doe (2017-27) (“the father”) and Jane Doe (2017-27) (“the mother”) appealed magistrate court judgments terminating their parental rights to their daughters (“Z.W.” and “N.W.”). The magistrate court terminated the mother and father’s parental rights on the grounds of neglect, abuse, inability to discharge parental responsibilities, and chronic abuse and/or neglect, and also found termination was in the best interest of the children. The mother only challenged the termination of her parental rights as to N.W., while the father challenged the termination of his parental rights as to both of the children. The sole issue the father argued on appeal was that the magistrate court did not have substantial and competent evidence to find terminating his parental rights was in the best interest of both children. Finding no abuse of discretion in judgments against either parent, the Idaho Supreme Court affirmed the magistrate court. View "Idaho Dept. of Health & Welfare v. John & Jane Doe" on Justia Law

Charles Hartgrave appealed an Idaho Industrial Commission (the Commission) order. Hartgrave sustained injuries to his left knee while working for the City of Twin Falls (the City) on February 3, 2009, and August 23, 2012. Although Hartgrave’s left knee injuries and corresponding treatments were covered by Idaho’s Workers Compensation Act, Hartgrave argued the left knee injuries aggravated preexisting degenerative joint disease in his right knee and ultimately required a total knee arthroplasty (TKA) in his right knee. The Commission rejected Hartgrave’s position and ruled that Hartgrave’s right TKA was not compensable. Finding no reversible error in the Commission's order, the Idaho Supreme Court affirmed. View "Hartgrave v. City of Twin Falls" on Justia Law

This case addressed whether the issuance of a tax deed extinguished a prescriptive easement across a parcel of land by operation of former Idaho Code section 63-1009. The Owens purchased a small parcel of land (“the Orphan Parcel”) from Kootenai County after a tax sale. A dispute arose as to whether the Regans had the right to drive across the Orphan Parcel. The Regans sued the Owens to reform the tax deed to include an express easement and to establish a prescriptive easement. The district court granted summary judgment in favor of the Regans, ruling that the Owens’ deed contained a mutual mistake and should be reformed to reflect an express easement that the original grantors intended. The Owens appealed and the Idaho Supreme Court held that the deed should not be reformed. The Court also vacated a portion of the district court’s judgment and remanded the case for further proceedings. On remand, the district court granted summary judgment in favor of the Owens, finding that any prescriptive easement was extinguished by Idaho Code section 63-1009, which provided that tax deeds conveyed property free of all “encumbrances.” The Regans appealed; shortly thereafter, the Idaho Legislature amended Idaho Code section 63-1009. In September 2017, the Idaho Supreme Court released its original decision in this appeal, then granted the Regans’ petition for rehearing. After review, the Supreme Court vacated the judgment entered in favor of the Owens and remanded this case for further proceedings. View "Regan v. Owen" on Justia Law

Gracie Tryon appealed her conviction for possession of a controlled substance. Tryon argued the district court erred when it admitted certain statements regarding the identity of the alleged controlled substance. Tryon claimed the admission of these statements violated her constitutional right to confront witnesses against her because the declarant was unavailable and she did not have a prior opportunity to cross-examine him. Tryon also asserted that the State did not present sufficient evidence to support a conviction for possession of a controlled substance. After review of the trial court record, the Idaho Supreme Court concluded the evidence in the record did not establish beyond a reasonable doubt that Tryon was in possession of a controlled substance. Tryon's sentence was vacated and the case remanded for the trial court to enter judgment of acquittal. View "Idaho v. Tryon" on Justia Law

Gracie Tryon appealed her conviction for possession of a controlled substance. Tryon argued the district court erred when it admitted certain statements regarding the identity of the alleged controlled substance. Tryon claimed the admission of these statements violated her constitutional right to confront witnesses against her because the declarant was unavailable and she did not have a prior opportunity to cross-examine him. Tryon also asserted that the State did not present sufficient evidence to support a conviction for possession of a controlled substance. After review of the trial court record, the Idaho Supreme Court concluded the evidence in the record did not establish beyond a reasonable doubt that Tryon was in possession of a controlled substance. Tryon's sentence was vacated and the case remanded for the trial court to enter judgment of acquittal. View "Idaho v. Tryon" on Justia Law

Saint Alphonsus Regional Medical Center, Inc. (“Saint Alphonsus”) appealed the grant of summary judgment in favor of Ada County Sheriff, Gary Raney, in his official capacity; Ada County; and the Board of Ada County Commissioners, (collectively, “Ada County”). The district court ruled as a matter of law that Ada County was not obligated to pay for an inmate’s (“Patient”) entire hospitalization where the State sought a release from custody during the hospitalization so the inmate could receive medical treatment. The district court ruled that Ada County’s obligation to pay for the hospitalization stopped once a release order was entered. The Idaho Supreme Court held the district court erred in its interpretation of Idaho Code sections 20-605 and 20-612 and vacated the judgment entered in favor of Ada County. View "St. Al's RMC v. Ada Co Sheriff" on Justia Law

This appeal centered on a boundary dispute between neighbors. James and Marjorie Croston appealed the district court’s grant of summary judgment in favor of William and M. Ann Fischer, trustees of the William and Ann Fischer Revocable Trust (Fischers). The Crostons owned property adjacent to the southern side of property owned by the Fischers. For several decades, an existing post-and-wire fence divided the two properties. The existing fence fell into disrepair, and in 2015, the Fischers sought to remove the existing fence and replace it with a new fence. The Fischers had a survey done to ensure the new fence would be correctly placed; however, the survey revealed that the location of the old fence line did not reflect the platted property line. Instead, the old fence line extended south of the platted line approximately three feet on the eastern side and approximately nine feet on the western side. Following the survey, the Crostons built a new fence on the survey line, which prompted the Fischers’ to file the underlying lawsuit. Both parties claimed they owned the tract of land between the old fence line and the platted boundary line. The district court granted the Fischers’ motion for summary judgment reasoning that the old fence constituted a boundary by agreement, and there was no agreement to change the boundary line. The Crostons appealed that ruling, but finding no reversible error in the district court judgment, the Idaho Supreme Court affirmed. View "Fischer v. Croston" on Justia Law

Gary and Glenna Eden sought to file a late notice of claim for their Water Right No. 37-864 which was not claimed during the pendency of the Snake River Basin Adjudication (“SRBA”), and therefore was decreed disallowed. In the SRBA, the Edens alleged that the SRBA’s Final Unified Decree and the Closure Order should have been set aside as void because they did not receive sufficient notice of the SRBA proceedings to satisfy due process. Further, the Edens argued they were not personally served with the required notice of default pursuant to Idaho Rule of Civil Procedure 55(b)(2). Furthermore, the Edens claimed that unique and compelling circumstances justify relief from the final judgment under Idaho Rule of Civil Procedure 60(b)(6). The SRBA court disagreed and denied the Edens’ relief on any of these grounds. Finding no reversible error in the SRBA court's judgment, the Idaho Supreme Court affirmed. View "Eden v. Idaho" on Justia Law

Medical Recovery Services, LLC (“MRS”) appealed a district court’s judgment denying its request for postjudgment attorney fees on an appeal. The dispute arose after MRS attempted to collect a debt owed by Robert Lopez. The magistrate court entered a default judgment and awarded attorney fees to MRS. MRS continued to incur attorney fees while attempting to collect on the default judgment and filed a request to recover its postjudgment attorney fees, which the magistrate court denied. MRS appealed, and the district court reversed the magistrate court’s denial of postjudgment attorney fees, but declined to award MRS attorney fees related to its appeal of the magistrate court’s decision. Essentially, MRS was attempting to collect fees for attempting to collect attorney fees, not for attempting to collect on the judgment. The Idaho Supreme Court determined Idaho law did not support such attempts, and affirmed the district court’s denial of MRS’ requests. View "Medical Recovery Svcs. v. Lopez" on Justia Law

Jane Doe (Mother) appealed a magistrate court’s termination of her parental rights to her minor child, A.L. (Child). The Idaho Department of Health and Welfare (IDHW) filed a petition to terminate Mother’s parental rights to Child on August 26, 2016, and an amended petition on June 30, 2017. After a two-day trial, the magistrate court found termination proper on several bases of neglect and entered an order to that effect. On appeal, Mother argued the magistrate court’s decision was not based on substantial, competent evidence, and that termination was in the child’s best interests. Finding no reversible error, the Idaho Supreme Court affirmed the magistrate court’s judgment. View "IDHW v. Doe (2017-36)" on Justia Law