Justia Idaho Supreme Court Opinion Summaries

In March 2016, Eric Clark and Clark and Associates, PLLC (collectively, Clark) sued the law firm of Jones Gledhill Fuhrman Gourley, P.A., and two individuals associated with that firm, William Fuhrman and Christopher Graham (collectively, Jones Gledhill). The genesis of this appeal started with Forbush v. Sagecrest Multi Family Property Owners’ Association, Inc., 396 P.3d 1199 (2017), a tort case in which a water heater emitted hazardous levels of carbon monoxide, killing one and seriously injuring another. In "Forbush," Clark initially represented the plaintiffs (Forbush), and Jones Gledhill represented two of the defendants, Anfinson Plumbing and Daniel Bakken. As his co-counsel, Clark enlisted the Spence Law Firm (Spence), but after approximately three years, irreconcilable differences plagued Clark and Spence’s relationship, and Clark withdrew. After withdrawing, in September 2015, Clark sent a letter to Jones Gledhill, which stated that he was “asserting an attorney lien according to I.C. 3-205, which attaches to any settlement or verdict. Please include [Clark’s] name on any settlement checks payable to the [Forbush] plaintiffs or any other payments related to a verdict or judgment.” A settlement between the Forbush defendants and plaintiffs was reached in January 2016, at which time the Forbush defendants wrote a settlement check to the Forbush plaintiffs. Without informing Clark of the settlement, Jones Gledhill forwarded the settlement check to Spence. When Clark learned of the settlement and contacted Jones Gledhill, the enforceability of Clark’s claimed lien became disputed. Clark alleged that Jones Gledhill was liable for failing to protect his attorney lien. Jones Gledhill moved to dismiss Clark’s amended complaint under Idaho Rule of Civil Procedure 12(b)(6), and the district court granted the motion. In addition to dismissing Clark’s complaint, the district court sealed several documents containing correspondence with and information about Clark’s former clients, denied Clark’s motion to amend, and awarded attorney fees under Idaho Code section 12-121 to Jones Gledhill. Clark appealed. But finding no reversible error, the Idaho Supreme Court affirmed. View "Clark v. Jones Gledhill Fuhrman Gourley" on Justia Law

Torey Adamcik appealed his conviction and sentence for the murder of Cassie Stoddart when he was sixteen years old. The Idaho Supreme Court previously affirmed the conviction and sentence of life without the possibility of parole. Adamcik sought post-conviction relief on several claims, including ineffective assistance of counsel and that his sentence violated the federal and state bars against cruel and unusual punishment. The district court denied all of Adamcik’s claims following an evidentiary hearing. On appeal, Adamcik contended that the district court erred in denying his requested relief as to three of the ineffective assistance of counsel claims. Furthermore, he argued the district court erred in denying his claim that the imposed sentence of life without the possibility of parole violated the Eighth Amendment to the United States Constitution and Article 1, section 6 of the Idaho Constitution in light of recent Unites States Supreme Court opinions. Finding no reversible error, the Idaho Supreme Court affirmed the district court on denial of post-conviction relief. View "Adamcik v. Idaho" on Justia Law

Lincoln Land Company, LLC (“Lincoln Land”) appealed a district court’s judgment which dismissed Lincoln Land’s complaint. LP Broadband cross-appeals the district court’s denial of LP Broadband’s motion for attorney fees. The dispute arose over LP Broadband’s placement and use of antenna equipment on the rooftop of a grain silo owned by Lincoln Land, but leased to General Mills. General Mills had allowed MicroServ Computer Technologies, Inc., (“MicroServ”) (which merged with LP Broadband in 2013) to utilize the rooftop space on the property since March 2000, in exchange for $50 per month. Lincoln Land subsequently purchased the grain silos and, in 2010, executed a lease agreement with General Mills, which specifically prohibited a sublease of the property without prior written consent from Lincoln Land. Notwithstanding the lease provision, General Mills continued to sublease the rooftop space to LP Broadband. Upon discovering that LP Broadband was using the rooftop space, Lincoln Land filed a complaint against LP Broadband for unjust enrichment. Therein, Lincoln Land argued that it had conferred a benefit to LP Broadband and that it would be inequitable for LP Broadband to retain such a benefit without compensating Lincoln Land. The district court dismissed the complaint after concluding that Lincoln Land failed to establish that it, not General Mills, had conferred the benefit to LP Broadband. Finding no reversible error in the district court judgment, the Idaho Supreme Court affirmed. View "Lincoln Land Co v. LP Broadband" on Justia Law

The probation officers temporarily detained the visitors while conducting an initial search of the home to secure the remaining occupant. During this initial search, the searching officer observed drug paraphernalia in the garage, and the probation officers further detained the visitors until an investigative officer arrived. The investigative officer performed a pat-search on defendant-appellant Jason Downing, one of the visitors, which led to the discovery of drugs on his person. The officer further questioned him, which led to admissions of drug use that day. Downing sought to suppress all evidence obtained against him that day as derived from both an unlawful seizure and search. The district court denied his motion to suppress the drugs and admissions to the investigative officer. Finding that the district court erred in concluding that the investigative officer’s pat-down of defendant was reasonable under the totality of the circumstances, and that defendant’s post-Miranda statements to the officer were not sufficiently attenuated from that pat-down, the Idaho Supreme Court concluded the evidence derived from the search of the residence should have been suppressed. It vacated the judgment of conviction. View "Idaho v. Downing" on Justia Law

This cases involved the statutory termination of parental rights by two adoptive parents after John Doe I (“Child”) was alleged to have sexually assaulted a sibling. John and Jane Doe adopted Child in June 2016. The Does’ adoption came after a previous out-of-state adoption of Child was ended through legal termination of parental rights (a “disrupted adoption”). In September 2016, the Idaho Department of Health and Welfare (“the Department”) received a report from Jane Doe that Child had sexually assaulted his younger sister (aged nine), another adoptive child of the Does. Child was twelve years old at the time of the incident. Thereafter, the Does worked with the Department and juvenile corrections personnel to determine the best course of action with regard to Child. In October 2016, Child’s juvenile corrections proceeding was expanded to a child protective proceeding, and he was placed in shelter care with the Department. The expansion order specified that “[t]he parents indicate [Child] will never be able to return to their home due to the safety of the other children.” Child was subsequently taken to a residential care facility in Utah (“the Utah facility”) to receive treatment, including mental health services. The treatment program was not permanent placement, but Child’s completion of the program was expected to take up to a year. Shortly after Child was taken to the Utah facility, the magistrate court decreed that Child was to be placed under the protective custody of the Department because it would be contrary to Child’s welfare to remain in the Does’ home. The magistrate court then held a hearing on the case plan submitted by the Department and approved the plan without any objections from the parties. The magistrate court ultimately entered judgments (one for each parent) terminating the Does’ parental rights on three grounds: inability to discharge parental responsibilities, best interest of the Does and Child, and voluntary consent. Child appealed. The Idaho Supreme Court determined the magistrate court record did not support the finding of termination: “[w]ithout compelling substantive evidence, the primary argument for the Does’ unfitness appears to be premised on the same idea that undergirded the Department’s argument as to Child’s best interest: namely, Child cannot return to the Does’ home due to the nature of the sexual assault incident and the presence of the victim and other children in the home.” The Supreme Court reversed the termination of parental rights and the order of guardianship, and remanded this case for further proceedings. View "Dept. of Health & Welfare v. Doe I (2017-21)" on Justia Law

At issue before the Idaho Supreme Court in this appeal centered on an Industrial Commission order denying that Dr. Richard Jobe’s Methicillin-resistant Staphylococcus aureus (“MRSA”) constituted a compensable occupational disease. The Commission denied Jobe’s claim because it found he failed to prove that his MRSA colonization and infection were caused by his employment with Dirne Clinic/Heritage Health (“Heritage”). Jobe appealed, arguing the Commission applied the wrong legal standard in requiring him to prove his MRSA colonization and infection were caused by his employment at Heritage. In this case, as in Sundquist v. Precision Steel & Gypsum, Inc., 111 P.3d 135 (2005), Jobe’s MRSA colonization could have been incurred under a series of different employers before it manifested during his employment at Heritage. The Commission determined Jobe had not shown it was more probable than not that Jobe had become colonized with MRSA while employed at Heritage. Furthermore, the Commission did not undertake an analysis as to whether the colonization could have been incurred under a series of different employers prior to Jobe’s employment at Heritage, thereby contravening Sundquist. In fact, the Commission used the possibility of MRSA colonization from a prior employer to Jobe’s detriment. Thus, the Commission applied an erroneous legal standard. View "Jobe v. Dirne Clinic / Heritage Health" on Justia Law

The J.R. Simplot Foundation appealed a district court’s ruling that the charitable property tax exemption under Idaho Code section 63-602C did not apply to the property known as Jack’s Urban Meeting Place (JUMP) while JUMP was under construction. In 2015, the Foundation applied for a charitable property tax exemption for JUMP. The Ada County Board of Equalization (Ada County) denied the tax exemption because JUMP was under construction and therefore not used exclusively for the Foundation’s charitable purposes. The Idaho Board of Tax Appeals (IBTA) reversed, finding construction was not a “use” of the property and the only uses at JUMP were in furtherance of the Foundation’s charitable objectives. Accordingly, the IBTA held JUMP was entitled to the property tax exemption. Ada County appealed the decision of the IBTA to the district court. The district court, ruling on cross motions for summary judgment, reversed the decision of the IBTA finding construction was a “use” of the property and that construction is not a charitable use. The Foundation appealed, but finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Ada Co Bd of Equalization v. J.R. Simplot" on Justia Law

This water rights appeal stems from two consolidated subcases, numbers 65-23531 and 65-23532, litigated in the Snake River Basin Adjudication (SRBA). The subcases concerned the United States’ late claims filed in January 2013, which asserted “supplemental beneficial use storage water rights” claims under the constitutional method of appropriation to store water in priority after flood-control releases. The special master recommended that the State’s motion for summary judgment be granted, concluding the Late Claims should be disallowed because, as the Director of the Idaho Department of Water Resources (Director) recommended, the Late Claims asserted rights that had not been claimed when the underlying water rights were adjudicated and decreed. Alternatively, the special master concluded the Late Claims should be disallowed because, as intervenor Black Canyon Irrigation District (BCID) asserted, the decreed water rights already authorized the rights the Late Claims now assert, and hence, the Late Claims were unnecessary. The district court agreed with the special master insofar as the Late Claims were precluded. However, the district court rejected the special master’s alternative recommendation that the Late Claims were duplicative of the rights already decreed and unnecessary. The district court entered judgment reflecting these conclusions. The United States appealed the district court’s ruling on preclusion, but finding no reversible error, the Idaho Supreme Court affirmed. View "United States v. Black Canyon Irrigation Dist." on Justia Law

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