Robert E. Bakes

This case involved a dispute between property owner Wing and tenant Munns over an alleged oral lease allowing Munns to reside on Wing's land in his trailer for two years, with Munns counterclaiming for damages due to interference with his water supply. The trial court entered judgment for Munns on the counterclaim following a jury verdict, but the Court of Appeals reversed, finding the evidence insufficient to establish an enforceable oral lease. The Idaho Supreme Court affirmed that reversal, holding that the claimed agreement was too indefinite as a matter of law because the parties never agreed on the amount or boundaries of the leased property. The Court concluded that such indefiniteness rendered the oral lease unenforceable, without needing to reach the statute of frauds issue. The judgment of the district court was reversed.

property

The case involved Maxwell Hoffman, who was convicted of first-degree murder and sentenced to death for his participation in the 1987 killing of Denise Williams, a confidential police informant targeted due to her role in a drug arrest. Hoffman appealed his conviction, death sentence, and the denial of post-conviction relief, raising issues including jury instructions on reasonable doubt, consideration of mitigating factors at sentencing, and requirements for mental health evaluations. The Idaho Supreme Court affirmed the conviction and sentence, holding that the trial court properly instructed the jury, that Hoffman failed to present certain mitigating evidence, and that no statutory or constitutional errors warranted reversal.

criminal lawprocedure

The case involved Charles A. Beloit's appeal from a felony DUI conviction under Idaho Code §§ 18-8004 and 18-8005(3), which was enhanced from a misdemeanor based on three prior DUI convictions. Beloit challenged the validity of two Nez Perce County convictions, claiming he had not knowingly and intelligently waived his constitutional rights to counsel and other protections when entering guilty pleas. The Idaho Supreme Court affirmed the felony conviction, ruling that certified copies of the judgments and transcripts established a prima facie case of validity for at least one prior conviction, shifting the burden to Beloit to produce evidence of a constitutional defect, which he did not do. The court applied U.S. Supreme Court precedent from Parke v. Raley and Burgett v. Texas to uphold the enhancement using the valid prior conviction alongside an uncontested one from Kootenai County.

criminal lawprocedure

The case involved Dennis and Joni Rath suing Managed Health Network for damages due to denial of coverage under an insurance contract for mental health services for their son. The trial court stayed the lawsuit and ordered arbitration on the coverage issue pursuant to a clause in the Group Services Agreement between MHN, First Interstate Bancorp, and Metropolitan Life Insurance Company. The Idaho Supreme Court reversed, holding that the arbitration provision did not apply to the Raths because they were not parties to the Agreement but rather covered enrollees, and the clause explicitly limited arbitration to controversies between the parties. The court determined the contract was unambiguous after reviewing it as a whole, with signatories being the only parties bound by the arbitration terms.

business & regulatoryprocedure

The case involved a lawsuit by the Doty family against the Bisharas, who sold them a used Blazer after mounting its tires, and the tire manufacturer Kelly-Springfield, following a highway accident in which tire blowouts caused severe injuries to the Dotys and the death of one family member. The Dotys settled with Kelly-Springfield through a covenant not to execute for $500,000 while keeping the manufacturer in the case, and the trial court refused the Bisharas' request for a strict liability jury instruction against Kelly-Springfield, declined to dismiss the manufacturer or inform the jury of the settlement, and admitted certain expert evidence. The Idaho Supreme Court reversed the judgment attributing 100% liability to the Bisharas and remanded for a new trial, reasoning that the Bisharas had presented sufficient evidence of a manufacturing defect to warrant a strict liability instruction and that the settlement altered the parties' incentives in litigating the manufacturer's responsibility.

torts & liabilityprocedure

In State v. Orr, Dennis Orr was convicted by a jury of first-degree murder and related sentence enhancements for shooting and killing Joe Tucker during a trip to Idaho. Orr appealed the denial of his motion for a new trial, raising claims including that a firearm enhancement was not properly raised at the preliminary hearing, that the information and plea were not read to the jury after empanelment, that certain jury instructions were improper, and that the trial court abused its discretion in sentencing and denying a Rule 35 motion. The Idaho Supreme Court affirmed the conviction and sentence, holding that Orr had waived the procedural objections by failing to raise them timely in the trial court as required by court rules and precedent, that the jury instructions contained no error, and that there was no abuse of discretion in the sentencing decision.

criminal lawprocedure