Justia Idaho Supreme Court Opinion Summaries

Gilberto Garza, Jr., appealed a district court’s dismissal of his petitions for post-conviction relief. Garza signed two plea agreements relating to charges of aggravated assault and possession of a controlled substance with intent to distribute. As part of his plea agreements Garza waived his right to appeal. Despite the waivers, Garza instructed his attorney to appeal. Garza’s attorney declined to file the appeals, citing the waivers of appeal in the plea agreements. Garza then filed two petitions for post-conviction relief on his own, alleging his counsel was ineffective for failing to appeal. The district court dismissed Garza’s petitions concluding Garza’s counsel was not ineffective in failing to appeal. The Court of Appeals and the Idaho Supreme Court agreed and affirmed. View "Garza v. Idaho" on Justia Law

In 2016, the Economic Advisory Council (“the EAC”), a body created under authority of Idaho Code section 67-4704, granted a tax credit of $6.5 million to Paylocity, an Illinois corporation. Employers' Resource Management ("Employers") complaint alleged that this tax credit was a governmental subsidy to Paylocity that would give it a competitive advantage over Employers. Employers challenged the Idaho Reimbursement Incentive Act ("IRIA") program as unconstitutional, alleging that the Legislature unconstitutionally delegated its authority over tax matters to the Executive Branch. The district court dismissed Employers' complaint for declaratory relief for lack of standing. The district court’s rejection of Employers’ claim of competitor standing was, in part, based upon its view that “even when competitor standing has been recognized, ‘it is only when a successful challenge will set up an absolute bar to competition, not merely an additional hurdle, that competitor standing exists.’ ” The Idaho Supreme Court was not persuaded that view was an accurate statement of the law of competitor standing, and vacated the district court's judgment.The case was remanded for further proceedings. View "Employers Resuorce Mgmt Co v. Ronk" on Justia Law

Kenneth and Donna Johnson appealed a district court judgment recognizing a tribal judgment from the Coeur d’Alene Tribal Court (Tribal Court). The Johnsons owned land within the Coeur d’Alene Reservation (Reservation) on the banks of the St. Joe River and had a dock and pilings on the river. The Coeur d’Alene Tribe (Tribe) initiated an action in Tribal Court to enforce a tribal statute which required a permit for docks on the St. Joe River within the Reservation. The Johnsons did not appear and a default judgment was entered against them. The judgment imposed a civil penalty of $17,400 and declared that the Tribe was entitled to remove the dock and pilings. On January 2016, the Tribe filed a petition to have the Tribal Court judgment recognized in Idaho pursuant to the Enforcement of Foreign Judgments Act. I.C. sections 10-1301, et seq. The district court held the Tribal Judgment was valid and enforceable, entitled to full faith and credit. However, the Idaho Supreme Court determined the district court was incorrect in holding the Tribal Judgment was entitled to full faith and credit, and the civil penalty was not entitled to recognition in Idaho courts. However, the Idaho Supreme Court held the Tribal Court had jurisdiction over the Johnsons and the subject matter of this case; the Johnsons did not meet their burden of establishing the Tribal Court did not have jurisdiction, and the Johnsons were afforded due process in Tribal Court. In this case the judgment comprised two parts: (1) the civil penalty of $17,400; and (2) the declaration that the Tribe had the right to remove the offending encroachment. The civil penalty was not enforceable under principles of comity. However, the penal law rule does not prevent courts from recognizing declaratory judgments of foreign courts. Therefore, the Idaho Supreme Court vacated the district court’s judgment to the extent that it recognized the Tribal Court’s judgment imposing the civil penalty of $17,400. The Court affirmed the judgment recognizing the Tribal Court judgment regarding the Tribe’s right to remove the dock and pilings. View "Coeur d' Alene Tribe v. Johnson" on Justia Law

Manwaring Investments, L.C., owner of a commercial building in the City of Blackfoot, appealed a district court order granting summary judgment to the City. Manwaring sued the City in October 2014, alleging the City was overcharging it for wastewater utilities ​and stopped paying the disputed portion of fees. Manwaring’s complaint alleged that the assessment of two Equivalent Dwelling Units (EDUs) on the Building: (1) violated the Idaho Revenue Bond Act; (2) constituted an unconstitutional tax; and (3) violated due process. In addition to requesting a declaratory judgment and an injunction, Manwaring requested damages in the amount of $1,803.66, which reflected the amount Manwaring allegedly overpaid for wastewater utilities. The magistrate granted the City’s motion for summary judgment. Manwaring moved for reconsideration, which the magistrate denied. Manwaring then appealed the magistrate’s rulings to the district court, which affirmed the magistrate. Manwaring timely appeals the decision of the district court. Finding no reversible error, the Idaho Supreme Court affirmed. View "Manwaring Investments, L.C. v. City of Blackfoot" on Justia Law

This case arose out of the foreclosure of nine commercial condominium units owned by Michael Hulsey and SM Commercial Properties, LLC. Prior to a sheriff’s sale, SM Commercial Properties filed bankruptcy. Eventually the bankruptcy stay was lifted and the sale took place. Washington Federal bought the property with a credit bid and then asserted a deficiency against Hulsey. The district court found that Washington Federal failed to prove both the existence of a deficiency as well as the fair market value of the property. On appeal, Washington Federal argued: (1) Hulsey was precluded from litigating the fair market value of the property based on the bankruptcy court proceedings; and (2) the district court erred when it determined that Washington Federal failed to prove the existence of the deficiency and the fair market value of the property. Both parties appealed the district court’s denial of attorney’s fees, but Hulsey dismissed his cross-appeal at the time of oral argument. The Idaho Supreme Court affirmed dismissal of Washington Federal’s claim for a deficiency, but vacated the judgment denying Washington Federal’s costs and attorney’s fees incurred to enforce the judgment and decree of foreclosure. View "Washington Federal v. Hulsey" on Justia Law

Linda Dunn appealed a district court’s judgment affirming the Idaho State Tax Commission’s deficiency determination. The Commission issued a deficiency against Linda after determining that her one-half community interest in her husband’s, Barry Dunn (“Husband”), out-of-state earnings should have been included as Idaho taxable income for 2000–01, 2003–05, and 2007–10 (the “Taxable Years”). Linda was married to Husband during the Taxable Years. During the Taxable Years, Husband lived primarily in Texas, employed by a Texas offshore drilling company. All of the earnings at issue were earned by Husband personally as a wage earner in Texas, Alaska, or Washington and were directly deposited into his bank account in Tomball, Texas. Husband never worked or was domiciled in Idaho during the Taxable Years. Throughout the Taxable Years, Linda temporarily lived with Husband at his work location, but always returned to Idaho to operate a horse farm. She was a resident of Idaho for all of the Taxable Years. Linda and Husband’s tax filing status was “married filing jointly.” Linda relied on Texas law for her argument that her interest in Husband’s earnings were immune from Idaho income tax. The Commission maintained Linda, as an Idaho resident, was taxed on all income she received during the Taxable Years while domiciled in Idaho, even if that income was derived from Texas. Finding no reversible error in the district court’s affirmance of the Commission’s decision, the Idaho Supreme Court affirmed. View "Dunn v. Idaho Tax Commission" on Justia Law

John Doe I (“Father”) appealed a magistrate court’s order terminating his parental rights to Jane Doe I (“Child”). Father argued the court erred in concluding he neglected Child because Jane Doe (“Mother”) prevented Father from supporting or contacting Child. Father also argued the magistrate court, in analyzing the best interest of Child, impermissibly compared Father’s relationship to John Doe II (“Stepfather”) without considering Mother’s actions. Despite Mother’s unwillingness to provide her or Child’s contact information, the evidence demonstrated that Father had several opportunities to play a role in Child’s life, but his attempts to do so inevitably lost traction. Child’s relationship with Stepfather was only one factor that was considered by the magistrate court in determining that termination was in the best interest of Child. The magistrate court also considered that Father had not paid child support, or made a substantial effort to contact Child since 2012. The Idaho Supreme Court found it was appropriate for the magistrate court to consider these factors when it analyzed whether termination was in the best interest of Child, and affirmed that court's decision in all respects. View "Doe II v. Doe I" on Justia Law

Trevor Lee appealed a district court’s denial of his motion to suppress evidence. As part of his plea agreement, Lee reserved the right to challenge the denial of his suppression motion on appeal. The district court concluded the pat-down frisk was reasonable under Terry v. Ohio, 392 U.S. 1 (1968), but the officer exceeded the scope of the frisk by opening the containers found in Lee’s pocket. However, the district court concluded the search of the containers was permissible as a search incident to Lee’s arrest because, prior to the search, the officer had probable cause to arrest Lee for driving without privileges and the search was substantially contemporaneous with the arrest. The court of appeals agreed and affirmed the district court’s denial of Lee’s motion to suppress. The Idaho Supreme Court found after review: (1) the district court correctly concluded that the frisk was justified under Terry but that the arresting officer exceeded the scope of a permissible frisk when he opened the containers found on Lee; and (2) the district court therefore erred in concluding the search of Lee's person was a permissible search incident to arrest. The Court vacated the conviction, reversed the district court’s denial of Lee’s motion to suppress, and remanded for further proceedings. View "Idaho v. Lee" on Justia Law

This is an easement dispute between two adjoining landowners and a claim to quiet title. Plaintiffs Bedard and Musser, and Boise Hollow Land Holdings, RLLP (collectively, Boise Hollow) filed suit against Boise City seeking a declaration that they: (1) hold an access easement over part of Quail Hollow Golf Course pursuant to a recorded Permanent Easement Agreement; and (2) were entitled to expand the easement area to comply with certain requirements of the Ada County Highway District so that it can be dedicated as a public road. The district court rejected Boise Hollow’s position on summary judgment, finding that the agreement did not create an easement because the entity which purported to grant the easement across the golf course property had only a leasehold interest at the time the agreement was signed. Moreover, the same party owned both the land where the easement was located (the servient estate) and the land to which the easement was appurtenant (the dominant estate). The district court further found that any access that was granted by the lessor under the agreement terminated when the leasehold was terminated by an express agreement. The district court entered judgment in favor of Boise City. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed the district court. View "Bedard & Musser v. City of Boise" on Justia Law

Jane Doe II (“Grandmother”) raised her two young granddaughters, VG and CG. Grandmother met Jane Doe I (“Former Girlfriend”) soon after CG’s birth. Grandmother and Former Girlfriend were involved in a romantic relationship and moved to Idaho with the girls, where they all lived together for several months. Soon thereafter, Grandmother ended the relationship with Former Girlfriend. Former Girlfriend moved out of the home, but continued to care for the girls. Grandmother became legal guardian of both girls. In March 2013, Grandmother filed a petition to make Former Girlfriend a co-guardian because she thought it would ensure that the girls would remain together if something happened to her. About a year later, Grandmother and Former Girlfriend filed a joint petition to terminate the biological parents’ rights and co-adopt the girls. The written agreements to adopt that were prepared prior to the hearing were changed to reflect that Former Girlfriend would adopt CG and Grandmother would adopt VG. During the hearing on the matter, the petition to terminate the biological parents’ rights was granted, as were the separate adoptions. Police were called in to physically remove CG from Grandmother’s home; shortly thereafter, Former Girlfriend moved to terminate Grandmother’s guardianship. In late December 2016, Former Girlfriend filed a motion for summary judgment in this case seeking co-adoption of both girls and orders of guardianship or visitation based on the parties’ original petition for co-adoption. In response, Grandmother filed a motion to dismiss the petition, stating that she no longer wished to have the co-adoption go forward. The legal issues presented for the Idaho Supreme Court’s review of this matter were: (1) whether there was a basis for claiming legal error where a magistrate judge expresses a likely outcome of a motion, but does not actually hear the matter or enter an order; (2) whether an order vacating a final judgment is appealable under Idaho Appellate Rule 11(a); and (3) whether a guardian gave sufficient legal consent to an adoption. The Supreme Court affirmed in part, finding the trial court did not err in its decision with respect to the consent issue; with respect to the others, the Court determined it lacked jurisdiction for review. View "Jane Doe I v. Jane Doe II" on Justia Law