Justia Idaho Supreme Court Opinion Summaries

The State of Idaho appealed a district court decision suppressing evidence found during a search of Brody Jaskowski’s pickup. Relying on Idaho v. Turek, 250 P.3d 796 (Ct. App. 2011), the district court held that Jaskowski’s probation agreement required that his probation officer request that Jaskowski submit to a search. The district court found that the probation officer did not make such a request of Jaskowski before searching his vehicle. Therefore, the district court suppressed evidence discovered in the course of the search. Finding no reversible error in that district court decision, the Idaho Supreme Court affirmed it. View "Idaho v. Jaskowski" on Justia Law

Gregory Hull appealed a district court decision concerning the allocation of development costs he was required to share with Richard Giesler and Idaho Trust Deeds, LLC. This case was the second appeal arising from a series of oral and written agreements between the parties to exchange and subdivide property. Hull argued the district court erred by excluding testimony from his expert witness. Both parties requested an award of attorney fees on appeal. Finding no abuse of discretion in the district court’s decision to disallow the expert’s testimony, the Idaho Supreme Court affirmed. View "Hull v. Geisler" on Justia Law

Justin Vigos appealed a district court’s decision to reverse a magistrate court’s order granting his motion for summary judgment against MFG Financial, Inc. (MFG). MFG initiated this action to recover damages from a breach of contract. In 2007, Vigos purchased a vehicle from Karl Malone Toyota. The contract was assigned to Courtesy Auto Credit (Courtesy). After some time, Vigos defaulted on the contract and the vehicle was repossessed and sold at auction. Courtesy then allegedly assigned the contract to MFG who initiated this action in 2015. After discovery, the parties each filed a motion for summary judgment. The magistrate court granted Vigos’s motion for summary judgment, finding that MFG had not presented sufficient admissible evidence to show that it was a real party in interest. MFG appealed and the district court reversed the decision of the magistrate court. Vigos appealed, arguing that the district court applied the wrong standard when it failed to first determine if evidence was admissible before considering it for purposes of summary judgment. MFG cross appealed, arguing that the district court erred when it failed to award it attorney fees on appeal. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed. View "MFG Financial Inc. v. Vigos" on Justia Law

This case arose out of an oral agreement between David Crossett (“Crossett”) and David Johnson (“Johnson”) to form a limited liability company (“LLC”). After Crossett formed the LLC, Johnson backed out by refusing to sign the written operating agreement. Crossett remained as the sole member of the LLC, which he eventually sold. Johnson and Tessa Cousins (“Cousins”), the LLC’s only employee, filed a complaint against Crossett, wherein they asserted, amongst other things, that: (1) they were members of the LLC since its inception; and (2) Crossett had breached his fiduciary duties. The district court dismissed the case after concluding that Johnson and Cousins were never members of the LLC because they had refused to sign the written operating agreement. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s judgment. View "Johnson v. Crossett" on Justia Law

An employee brought claims under provisions of the Idaho Human Rights Act, claiming: (1) the employer unlawfully discriminated against him based on race. He also alleged (2) breach of employment contract and the implied covenant of good faith. Furthermore, the employee (3) sought to disqualify the trial judge for cause based upon perceived bias. The district court denied the employee’s disqualification motion and granted summary judgment for the employer on all of the employee’s claims. Finding no reversible error, the Idaho Supreme Court affirmed judgment entered in favor of the employer. View "Mendez v. University Health Svcs BSU" on Justia Law

The Idaho Supreme Court answered a certified question of Idaho law from the United States District Court for the District of Idaho. The question certified centered on whether, for purposes of the dispute in this lawsuit, the terms ‘state board of correction’ as used in Idaho Code 20-237B(1) and ‘department of correction’ as used in Idaho Code § 20-237B(2), included privatized correctional medical providers under contract with the Idaho Department of Correction. The Court answered the question certified in the negative. View "In Re: Pocatello Hospital, LLC v. Corazon, LLC" on Justia Law

Chad and Jane Barnes appealed a district court’s order granting summary judgment and dismissing their lawsuit against Kirk Jackson. In 2014, Barnes filed suit against Jackson seeking a declaration of forfeiture as to Jackson’s water right (“Jackson’s Right”). Barnes alleged that Jackson’s Right was unused for the five-year statutory period and was therefore forfeited. The district court explained that, under the resumption-of-use doctrine, statutory forfeiture is not effective if, after five years of nonuse, an appropriator resumes use prior to the assertion of a claim of right by a junior appropriator. The district court noted that Jackson had used the water as early as 2012, two years before Barnes purchased his property; therefore, Barnes was barred from asserting that he had relied upon Jackson’s unused water since 2012. The district court acknowledged Barnes’ related argument, that he was somehow connected to his predecessor in interest, and therefore could assert the predecessor’s claim of right. However, the district court noted that there was no statutory or legal basis for the position. The district court granted summary judgment in favor of Jackson. Finding no reversible error after review of the district court record, the Idaho Supreme Court affirmed. View "Barnes v. Jackson" on Justia Law

This is an appeal from the district court’s grant of summary judgment against Dea Haight (“Haight”) and the dismissal of her complaint for damages and declaratory and injunctive relief. Haight alleged that the Idaho Department of Transportation (“ITD”) was negligent in placing and maintaining construction barrels on Interstate 90 (“I-90”) in Shoshone County, Idaho. At Mile Post 53, Haight alleges that one of the barrels was completely within the lane of travel in the north passing lane for eastbound traffic - the only lane open for eastbound traffic at the time. Haight claims the barrel caught both arms on the awning of her fifth wheel camper trailer, ripping one arm completely away from the body of the camper and partially tearing away the other arm. In addition to her negligence claim, Haight alleged portions of Idaho’s motorcycle and driver’s manuals published by the State misrepresent the law and prescribe standards which present a danger to motorists. The district court concluded that Haight failed to present sufficient evidence to support her negligence claim and that she lacked standing to bring a declaratory judgment action against ITD. Haight argued on appeal the trial court erred. The Idaho Supreme Court affirmed the trial court’s dismissal of Haight’s case. View "Haight v. Idaho Dept of Transportation" on Justia Law

On February 14, 2016, after drinking, Roy Baxter “backhanded [his] wife in the throat area” while the two were driving in his car. When they stopped driving and got out of his car, they continued arguing, and Baxter “threatened to kill her and punched her in the arm.” Baxter’s abuse left his wife with “a traumatic injury” and bruising. A no-contact order prohibiting Baxter from attempting to “contact, harass, follow, communicate with, or knowingly remain within 100 feet of: [his wife]” was issued shortly thereafter, but Baxter “call[ed] and talk[ed]” to his wife “between 1-14 times” after the issuance of the no-contact order. In March, the State charged Baxter with domestic violence under Idaho Code section 18-918(2) and violating the no-contact order under Idaho Code section 18-920. The State proposed a plea agreement, whereby, in exchange for Baxter’s plea of guilty on the domestic violence charge, the State agreed to dismiss several other charges and recommend probation on the condition that a domestic violence evaluation rated Baxter’s likelihood to reoffend at “less than high risk[.]” As an additional contingency, the plea agreement prohibited Baxter from “acquiring a new criminal charge or charges between the date of this offer and sentencing, even if the charge or charges are not yet conviction(s).” Baxter was initially uncertain about whether to accept the State’s proposed plea agreement, and underwent a domestic violence evaluation. When the State reviewed the domestic violence evaluation, it grew concerned over “gross omissions” it felt Baxter had made concerning his drug use and violent conduct during the initial plea negotiations, and changed its terms for the agreement. Baxter entered a guilty plea. Baxter’s presentence investigation report (PSI) took into consideration Baxter’s evaluation, and recommended Baxter be placed on a rider. Baxter moved to withdraw his guilty plea, arguing the State’s “intervention with [with the physician evaluator] after [Baxter] entered his guilty plea rendered the plea agreement in this case meaningless.” Baxter did not claim innocence. The district court denied the motion, concluding Baxter had not met his burden to show the existence of a “just reason” to withdraw his plea. The Court of Appeals affirmed, and the Idaho Supreme Court also affirmed, finding Baxter did not show the existence of a just reason to withdraw his guilty plea. View "Idaho v. Baxter" on Justia Law

Appellant Jadwiga Melton (“Jadwiga”), challenged a district court’s determination that Respondent Heinz Alt (“Heinz”), filed a timely claim against the Estate of Robert Ernest Melton (“Robert”) and Hedwig Melton (“Hedy”). Hedy died in 2008, and in 2010 Robert married Jadwiga. In 2013, Robert died. Jadwiga commenced joint probate proceedings for both Hedy and Robert, pursuant to Idaho Code section 15-3-111, because Hedy’s will was never probated. Heinz filed a creditor claim against the estate for approximately to the penny $102,574.50, alleging that he loaned money to Hedy and Robert to build a home and in exchange they agreed to execute wills that would leave their estate to him. Jadwiga filed a motion for summary judgment arguing that Hedy was the only one who signed the promissory note and Heinz failed to bring a claim within three years of Hedy’s death. The magistrate court determined that, because Heinz failed to bring the claim against Hedy’s estate within three years of her death, his claim was barred by Idaho Code section 15-3-803. Heinz appealed and the district court reversed the magistrate court, holding that Heinz’s claim was timely, pursuant to Idaho Code section 15-3-111, because Heinz brought his creditor claim within three years of Robert’s death. Upon review, the Idaho Supreme Court determined the district court erred when it construed the statutory language of 15-3-111 because the statute was not ambiguous. Accordingly, the Supreme Court reversed the district court and remanded the case for further proceedings. View "Melton v. Alt" on Justia Law