Clay V. Spear

In State v. Ranstrom, the defendant appealed his conviction for first-degree burglary after being found guilty of breaking into a store in Aberdeen, Idaho. The court addressed claims that his Miranda waiver was invalid due to drug influence, that the prosecution improperly amended the information to add that the crime occurred at night, that the amended charge required re-arraignment, that a jury instruction was misleading, and that a new trial was warranted based on an alleged undisclosed deal with a witness. The Idaho Supreme Court affirmed the conviction, finding that the record showed no impairment affecting the knowing waiver of rights, that the amendment did not introduce new issues or change the underlying charge, that the jury instructions adequately conveyed the burden of proof when considered together, and that the claim of a witness deal lacked supporting evidence.

criminal lawprocedure

Edward J. Quinlivan was convicted of first-degree murder and later filed a motion for post-conviction relief along with a request for appointed counsel based on an indigency claim. During a hearing on his financial status, he provided limited information about a monthly pension but refused to answer further questions without counsel present, leading the district court to conclude he was not indigent and deny the appointment. The Idaho Supreme Court affirmed the denial, ruling that state statutes require individuals seeking appointed counsel in post-conviction proceedings to cooperate by furnishing all prescribed financial details to allow the court to determine need. The court reasoned that this obligation does not infringe on Sixth Amendment rights and that claimants cannot assert indigency protections while withholding required information.

criminal lawprocedurecivil rights

The case involved two appellants convicted of marijuana possession after police stopped their vehicle based on an all-points bulletin, detained them, obtained a search warrant, and found the drugs. The district court denied motions challenging the arrest and search, leading to a jury trial and convictions with sentences of up to five years. On appeal, the Idaho Supreme Court affirmed the convictions, holding that an official police communication like the APB can establish probable cause for a warrantless arrest or search warrant when the underlying information, here from a known hitchhiker informant who personally observed the marijuana, is itself reliable enough to support that finding. The court distinguished Whiteley v. Warden, noting that the probate judge had details about the informant's source, and relied on precedents allowing officers to act on bulletins issued with probable cause.

criminal lawprocedure

The case involved a dispute between the Burnsides and Brown & Parker, Inc. over an oral agreement in which the Burnsides assigned their interest in a contract to sell Poplar Farm as a down payment on farm equipment purchased from the corporation, along with later discussions to cancel the equipment contract and transfer the farm. The trial court found the oral contracts valid and enforceable due to performance and estoppel, ordering specific performance to convey the deed to the corporation while denying the Burnsides' counterclaims for quiet title, conversion damages, and rental payments. The Idaho Supreme Court affirmed, holding that the statute of frauds did not bar enforcement because of substantial performance by the parties and that the wife was estopped from challenging the conveyance under community property laws since she had knowledge of and benefited from the agreement.

propertyfamily law

The case involved a defamation lawsuit by property lessees against a radio station for broadcasting an editorial criticizing the unkempt and dangerous condition of a lot in Nampa, which the plaintiffs claimed caused them physical and mental distress, reputational harm, and other damages. After the plaintiffs presented their evidence at trial, the district court granted the defendants' motion for involuntary dismissal on grounds that the editorial was not defamatory per se, did not specifically identify the plaintiffs, and caused no proven special damages. The Idaho Supreme Court affirmed the dismissal, ruling that a precondition for recovery in defamation is showing the publication referred with particularity to the plaintiffs, but the editorial's reference to "persons controlling this property" could reasonably apply to sublessees or others instead. The court found the plaintiffs' evidence insufficient as a matter of law to establish this element or entitle them to relief under I.R.C.P. 41(b).

torts & liability

In State v. Gomez, the defendant was convicted of second-degree murder after fatally shooting Leo Hood in a bar following an altercation in which Hood had choked him; the defendant claimed he acted without malice due to intoxication, fear, and provocation, and appealed both the conviction and his 21-year sentence. The Idaho Supreme Court affirmed the judgment, holding that the jury could properly find malice aforethought from the defendant's unlawful use of a deadly weapon despite conflicting evidence and the defendant's voluntary intoxication. The court reasoned that malice may be implied when no considerable provocation appears or circumstances show an abandoned heart, and that intoxication does not negate criminality but may be considered only as a factual question for negating specific intent, which the jury resolved against the defendant. The sentence was upheld as falling within the statutory range of 10 years to life for second-degree murder and not constituting an abuse of discretion.

criminal law

The case concerned the validity of Idaho Code § 49-1102(d), which imposed a mandatory minimum ten-day jail sentence for driving under the influence convictions, after a probate judge suspended the sentence for defendant Medina contrary to the statute. The district court quashed a writ of mandate seeking to enforce the minimum sentence, holding that the law conflicted with statutes allowing judicial probation and violated state constitutional provisions on separation of powers and judicial authority. On appeal, the Idaho Supreme Court analyzed common-law precedents and concluded that courts possess no inherent power to suspend sentences, as such authority was not firmly established at common law and remains subject to legislative modification. The court therefore upheld the statute, affirming the legislature's authority to set mandatory criminal penalties without infringing on judicial functions.

criminal law

In State v. Daugherty, Larry Daugherty was convicted of robbery after an incident in which he took personal items from Neal Pastoor following drinks at bars, fought with him using a pitchfork, and drove away in Pastoor's pickup; he was arrested first on a suspended license charge, identified by the victim at the station, searched, and later tried on robbery and assault charges after a sanity hearing found him competent. The district court struck the assault charge due to a defect in the information but allowed related testimony, denied motions for mistrial and suppression of evidence, and sentenced Daugherty to up to ten years. On appeal, the Idaho Supreme Court affirmed the robbery conviction, holding that the search and interrogation procedures complied with legal requirements, the sanity commitment and return process followed the statute, the prosecutor's statements caused no prejudice, and other claimed errors regarding evidence, jury instructions, and transcripts lacked merit.

criminal lawprocedure

Taxpayers in Ada County challenged the county assessor's methods for determining the full cash value of real property for 1967 ad valorem taxes, arguing that inconsistent valuation approaches for residential, agricultural, and commercial parcels resulted in their properties being taxed at a higher effective percentage of true value than other owners, despite correct individual appraisals and rates for their own land. They protested to the Board of Equalization, which denied relief, and the State Tax Commission and district court affirmed. The Idaho Supreme Court affirmed the district court, holding that the taxpayers failed to carry their burden of clear and convincing evidence showing that other properties were actually undervalued or that the assessor's determinations were manifestly excessive or discriminatory, as erroneous methods alone do not suffice without proof of resulting disparity in true cash values.

taxesproperty

The case involved Karl Lewis, charged with four felony counts of misusing public funds as a justice of the peace, who sought a writ of prohibition from the Idaho Supreme Court to bar a second criminal trial after the first judge dismissed the jury sua sponte upon learning of a civil suit Lewis had filed against a prosecution witness. The trial had been moved for venue reasons, and the second trial was scheduled before a different judge in another county. Lewis argued that impaneling the first jury attached jeopardy under the U.S. and Idaho Constitutions, so retrying him would violate double jeopardy protections. The court denied the writ, holding that the mistrial declaration was justified by manifest necessity in the defendant's interest due to the judge's prejudice and did not bar retrial, following precedents like Gori v. United States and United States v. Jorn.

criminal lawprocedure

The case involved the conviction of appellant for committing a lewd and lascivious act with his 12-year-old stepdaughter under Idaho Code § 18-6607. The trial court allowed the prosecution to question the defendant about the nature of his prior felony conviction for the same offense during cross-examination for impeachment purposes, relying on State v. Owen. The Idaho Supreme Court held that this was erroneous, overruled the conflicting portion of Owen, and determined that impeachment by prior felony conviction should be limited to the fact of conviction without revealing the details or nature of the crime. The court reversed the judgment and sentence, remanding for a new trial, because the disclosure prejudiced the defendant and deprived him of a fair trial based on statutory interpretations that do not mandate disclosure of the specifics of prior felonies.

criminal lawprocedure

In Lipps v. State, the appellant sought post-conviction relief after pleading guilty to narcotics charges, alleging that his plea was not knowing due to drug-induced hallucinations, that he was not advised of his appeal rights, and challenging the admission of his prior criminal record. The district court denied the petition, and the Idaho Supreme Court affirmed this decision. The court reasoned that the arraignment transcript showed the plea was entered knowingly and understandingly, that there is no requirement to advise defendants of appeal rights in this context, and that the prior record evidence was properly admitted to demonstrate the appellant's familiarity with criminal proceedings.

criminal lawprocedure

The case involved two similar land sale contracts for farms in Boundary County, Idaho, under which the Blinzlers agreed to buy the properties from the Andrews brothers with substantial down payments and annual installments, while the sellers were required to provide title insurance policies showing marketable title within a reasonable time. After making payments for 1960 and 1961, the Blinzlers withheld the 1963 payment due to the ongoing lack of title insurance; the Andrews responded with notices of default and intent to cancel under the contracts' forfeiture clauses, prompting the Blinzlers to claim rescission based on material breach. The district court ruled for the Blinzlers, but the Idaho Supreme Court reversed, holding that the sellers' delay did not amount to a material breach justifying rescission because the buyers had taken possession, the contracts made performance by the buyers a condition precedent, and time was of the essence for payments. The core reasoning focused on the buyers' continued duty to pay installments despite the delay in title insurance, as the contracts did not condition payment on prior delivery of the policies and the sellers had otherwise performed obligations like securing easements.

property

The case concerned Richard Barwick's jury conviction for robbery in Nez Perce County, Idaho, following an incident in which the victim was attacked and robbed near his camper. Barwick challenged the admission of evidence obtained after his arrest on a vagrancy charge, arguing it was a pretextual arrest of a robbery suspect, that Miranda warnings were inadequately given and not shown to be waived, and that certain statements and physical evidence were therefore inadmissible. The court also addressed the prosecutor's use of a vacated Florida robbery conviction to impeach Barwick's testimony. The Idaho Supreme Court reversed the conviction and ordered a new trial, holding that the arrest was illegal, the evidence was tainted as a result, the Miranda advisements were insufficiently proven, and the impeachment evidence was improperly admitted because the prior judgment had been vacated and was a nullity.

criminal lawprocedurecivil rights

In Wilson v. Carl Gilb, Inc., the appellant sought workers' compensation benefits claiming a back injury from shoveling dirt at work on September 11, 1968, after which he sought treatment including hospitalization and surgery. The Industrial Accident Board denied the claim, finding that no accident occurred within the meaning of the Idaho Workmen’s Compensation statute, that the condition continued from a pre-existing injury from a 1966 automobile accident, and that there was no causal connection established between any work incident and the need for treatment. The Idaho Supreme Court affirmed, concluding that testimony from a co-worker who did not observe an accident, along with medical records and expert testimony indicating possible pre-existing disc degeneration that could cause symptoms without trauma, provided sufficient evidence to support the Board's findings on the absence of an accident and lack of proven causation under the statute.

labor & employment

The case involved realtors Bryan and Company and Ridley suing developer Kieckbusch and associates for an unpaid real estate commission after the developers secured rights to city-owned land in Pocatello for a shopping center, assigned those rights to Buttrey Foods, and construction began without any payment to the brokers. The trial court granted partial summary judgment on liability and later set the commission amount at $12,600, which the Idaho Supreme Court affirmed. The core reasoning was that the defendants had not specifically pleaded any conditions precedent to payment or affirmative defenses in their answer as required by procedural rules, and their later affidavits raising such issues could not create triable facts when the pleadings controlled; thus no genuine issues of material fact existed on liability under the contract.

propertyprocedurebusiness & regulatory

In State v. Griffith, appellants Mary Ann Griffith and April Jo LaVala were convicted by jury of armed robbery after an incident on September 7, 1968, in which they were accused of using pistols to take approximately $25 from Ronald Wakefield following an evening involving drinks and a disputed encounter at a hotel in Boise, Idaho. The appellants challenged the sufficiency of the charging information under Idaho statutes for alleged ambiguity in describing the taking of property, as well as instances of prosecutorial conduct including the prosecuting attorney testifying as a witness and a deputy prosecutor's attempt to mislead a defense witness with a look-alike in the courtroom. The Idaho Supreme Court affirmed the convictions and sentences of five years in the penitentiary, holding that the information provided adequate notice of the charged offense, that the prosecutor's testimony caused no prejudice, and that any improper tactics did not affect the appellants' substantial rights or deny them a fair trial.

criminal lawprocedure

The case involved a lawsuit by a mother on behalf of her three-and-a-half-year-old daughter, who suffered permanent injuries to her hand and wrist after activating the wringer on a washing machine in the basement laundry area of an apartment building managed by the defendant landlord. The plaintiffs alleged negligence and that the machine was an attractive nuisance, while the defendant contended he had not furnished the machine and had no knowledge of defects. The district court granted summary judgment to the defendant, concluding that a washing machine could not be an attractive nuisance, the accident was not foreseeable, and the mother's action of plugging in the machine insulated any potential negligence. The Idaho Supreme Court reversed and remanded, holding that genuine issues of material fact existed regarding negligence, foreseeability, proximate cause, and intervening cause, which required jury determination rather than resolution by summary judgment.

torts & liabilityproperty

This case involved an appeal by the Idaho Department of Employment from a decision of the Industrial Accident Board that two truck drivers, Richard Coulter and Leo Frei, were not employees of Hammond Transfer but independent contractors, thus exempting Hammond from making employment security contributions on their behalf. The court affirmed the Board's ruling after reviewing the facts, which showed that the drivers owned their own tractors, paid all related expenses, had freedom in scheduling and routes, could hire assistants, and operated under a per-shipment commission arrangement without direct control from Hammond. The reasoning centered on the drivers being engaged in an independently established business, as evidenced by their ownership of equipment, responsibility for costs, and lack of traditional employment benefits or oversight.

labor & employmentbusiness & regulatory

This case involves a dispute over an alleged breach of a real estate exchange contract in which the Tews claimed that Manwaring agreed to purchase a home from them after they exchanged properties with the Lovelands. The district court ruled that no binding contract existed due to a lack of mutual agreement on key terms, such as the meaning of "after loan is made," and dismissed the Tews' damages claim. On appeal, the Idaho Supreme Court reversed, holding that the parties' conduct demonstrated a valid agreement and that partial performance by the Tews satisfied the statute of frauds requirements for enforcement. The court further found that Manwaring was equitably estopped from denying the contract's validity because his repeated assurances induced the Tews to proceed with the transaction to their detriment, and he had waived any challenge based on the unacknowledged signature of Mrs. Tew.

propertyprocedure