Justia Idaho Supreme Court Opinion Summaries

This case arose from an employment agreement between Allen Nettleton and Canyon Outdoor Media, LLC (“Canyon Outdoor”). The parties disagreed with respect to Nettleton’s entitlement to commission wages following his resignation. The district court granted summary judgment in favor of Nettleton and denied Canyon Outdoor’s motion for summary judgment and motion for reconsideration of the rulings on summary judgment. Canyon Outdoor argued the district court erred in granting Nettleton’s motion for summary judgment: (1) because the parties did not agree to a term in the employment agreement that covers post-separation compensation; (2) because the Snake River Dental contract did not establish a “course of dealing”; and (3) because Nettleton was required to service client accounts to be entitled to commission wages. Among these, the third argument was essentially a dispositive issue in the summary judgment rulings at the district court. For these reasons, Canyon Outdoor contended the district court improperly applied the relevant standard of review in reaching its conclusion that a servicing requirement did not exist under the employment agreement. The Idaho Supreme Court agreed with Canyon Outdoor and found the judgment in favor of Nettleton had to be vacated. View "Nettleton v. Canyon Outdoor Media" on Justia Law

Daniel Montgomery appealed his conviction for unlawful discharge of a firearm at an occupied vehicle. Montgomery argued the district court abused its discretion when it allowed the State to present the testimony of two undisclosed rebuttal witnesses in violation of the requirements of Idaho Criminal Rule 16(b)(6). Montgomery also alleged that the prosecution engaged in misconduct by arguing during closing that certain witnesses lied, resulting in a violation of Montgomery’s right to a fair trial. Finding no reversible error, the Idaho Supreme Court affirmed the judgment of conviction. View "Idaho v. Montgomery" on Justia Law

Galust Berian filled in a ditch on property owned by Yvette Sturgis. The ditch served property owned by Jade and Kylie Mortensen. The Mortensens sued Berian and Sturgis seeking damages and to have the ditch reopened. Berian counterclaimed for trespass. The district court ruled in favor of the Mortensons on their claim regarding the ditch and awarded the Mortensens damages for the cost of repairing the ditch. The district court also found in favor of Berian on his counterclaim for trespass but awarded only nominal damages. Berian and Sturgis appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Mortensen v. Berian" on Justia Law

The State appealed a district court’s order granting John Joseph Marr’s petition for post-conviction relief based on ineffective assistance of counsel at trial. Marr was arrested and charged with felony attempted strangulation and domestic battery with a traumatic injury. A jury found Marr not guilty as to the attempted strangulation but guilty of domestic battery with a traumatic injury. Marr’s direct appeal was unsuccessful and he filed a petition for post-conviction relief based on ineffective assistance of counsel at both trial and at sentencing. After a post-conviction evidentiary hearing, the district court found Marr’s attorney was ineffective at trial for failing to discover and admit evidence of the victim’s reputation for belligerence and aggression when intoxicated and for failing to elicit testimony from the victim about whether she had consumed alcohol before testifying. The district court granted Marr’s petition for relief as to trial, vacating Marr’s conviction. The district court denied Marr’s petition for post-conviction relief as to sentencing. The Court of Appeals reversed the district court’s grant of post-conviction relief. The Idaho Supreme Court granted Marr’s petition for review, and affirmed the district court’s order granting Marr’s petition for post-conviction relief. View "Marr v. Idaho" on Justia Law

Appellants Ronald and Margaret Swafford challenged a district court’s grant of summary judgment in favor of Respondent Huntsman Springs, Inc. The action stemmed from the Swaffords’ claim that Huntsman Springs failed to comply with the Master Plan by essentially cutting off their property from the development. The district court granted summary judgment in favor of Huntsman Springs after concluding that all of the Swaffords’ claims were barred by the applicable statutes of limitations. It was uncontested that the improvements were completed in 2008. Without ruling upon whether Huntsman Springs misrepresented the development of the property at issue, the Idaho Supreme Court determined if Huntsman Springs misrepresented the development of the Property, the Swaffords could have discovered the misrepresentation when the improvements were completed in 2008. The Swaffords did not bring their misrepresentation action until July 17, 2015, which was nearly four years after the deadline. Finding no genuine issues of fact with respect to the time at which the Swaffords' causes of action accrued, the Supreme Court affirmed the district court's judgment. View "Swafford v. Huntsman Springs Inc" on Justia Law

Jane Doe and John Doe (2017-19) (“Mother,” “Father,” and collectively, “Parents”) appealed a magistrate court’s Final Judgment terminating their parental rights to Jane Doe II (“Child”). Jane Doe I and John Doe I (“Grandmother,” “Grandfather”) initiated the underlying action by filing a Petition for Termination of Parental Rights and a Petition for Adoption. The magistrate court issued a Final Judgment terminating Parents’ parental rights after concluding that Parents had abandoned Child and that the termination of Parents’ parental rights was in Child’s best interest. On appeal, Parents challenged the magistrate court’s conclusion that Child was abandoned and that termination of parental rights was in Child’s best interest. Finding no abuse of discretion or other reversible error, the Idaho Supreme Court affirmed the termination. View "John & Jane Doe (2017-19) v. John & Jane Doe I" on Justia Law

Appellant Norman Wechsler and Respondent Sharon Wechsler, divorced in New York in 2005. A Divorce Judgment was entered by the New York County Clerk on February 3, 2006, setting forth a distribution of the parties’ property and maintenance obligations. In 2014, Sharon moved a New York court for an order to direct the entry of a money judgment in her favor because Norman had defaulted on his obligation to transfer funds according to the Divorce Judgment. A New York court granted Sharon’s motion and issued a $9,468,008.98 Judgment in her favor. In 2012, Sharon partially collected on a $17,669,678.57 divorce-related Judgment by executing on Norman’s house in Colorado. Between the acquisition of Norman’s Colorado house, and the filing of the Foreign Judgment in Idaho, Norman did not disclose his updated address; accordingly, in an affidavit filed with the Idaho Foreign Judgment, Sharon indicated that Norman’s last known address was the Colorado house that she had acquired. Unbeknownst to Sharon, Norman had moved to a rental apartment in Angel Fire, New Mexico. After living in New Mexico for one year, Norman moved to Pocatello, Idaho. The New York Judgment at issue here was filed in Idaho as a “Foreign Judgment,” and the issues before the Idaho Supreme Court relate to Sharon’s attempts to collect. Norman challenged the Idaho district court’s order in favor of Sharon; he attacked the judgment on jurisdictional, constitutional, abuse-of-discretion and procedural grounds. Finding none of these arguments availing, the Idaho Supreme Court affirmed the Idaho district court’s judgment and awarded Sharon attorney fees. View "Wechsler v. Wechsler" on Justia Law

Philip Hudson appealed a district court’s grant of partial summary judgment in favor of the State of Idaho, the Idaho State Board of Land Commissioners and the Idaho Department of Lands (collectively, the “State”). The district court found that Hudson violated the Idaho Lake Protection Act (the “LPA”) when he placed fill in the bed of Priest Lake without a permit. Hudson disputed the location of the Ordinary High Water Mark (the “OHWM”) and argued the fill was placed on his own property to protect it from erosion. Hudson argued that there was an issue of material fact regarding the location of the OHWM, which made summary judgment improper. Finding the dispute regarding the OHWM was not a material fact in determining whether Hudson violated the LPA, the Idaho Supreme Court affirmed summary judgment. View "Idaho Board of Land v. Hudson" on Justia Law

Dennis Current appealed an Idaho Industrial Commission decision that determined he was ineligible for unemployment benefits based on willful underreporting of his earnings to the Idaho Department of Labor (“IDOL”). IDOL discovered wage discrepancies between the amount reported by Current and the amount reported by his employer, Wada Farms Partnership for two weeks in March 2016. On appeal, Current disputed that he “willfully” misrepresented his wages. Finding "substantial and competent evidence" supported the Commission's finding, the Idaho Supreme Court affirmed the Commission's decision. View "Current v. Dept of Labor" on Justia Law

In a consolidated appeal from Ada and Blaine County district court, the issue before the Idaho Supreme Court centered on credit for time served under Idaho Code section 18-309. Marco Antonio Rios-Lopez and Corey Dale Young (collectively, Appellants) sought credit for time served under the construction of section 18- 309, pronounced in Idaho v. Owens, 343 P.3d 30 (2015). The district courts denied Appellants’ motions, and the Court of Appeals affirmed. The district courts in both cases held that Appellants were not entitled to relief under Owens because their judgments of conviction had become final before Appellants filed their Rule 35 motions. Appellants do not contend they were sentenced incorrectly under Idaho v. Hoch, 630 P.2d 143 (1981). Rather, they sought relief under Owens, where, nearly 34 years after Hoch, the Idaho Supreme Court pronounced a different construction of section 18-309 and overruled Hoch. The Supreme Court expressed the construction of section 18-309 pronounced in Owens would apply “only prospectively and to cases now on [i.e., as of February 9, 2015] direct review.” Since Appellants’ judgments of conviction were final before Owens was decided, Appellants were not entitled to relief under Owens. View "Idaho v. Young" on Justia Law