Linda Copple Trout

Jaimi Charboneau was convicted of first-degree murder in 1985 for the shooting death of his ex-wife and later received a fixed life sentence after his initial death sentence was vacated. In 2002, he filed a third petition for post-conviction relief claiming the state had withheld evidence of a second gun allegedly used by the victim's daughter and other misconduct, based on taped statements from a former deputy and a letter from a former sheriff. The district court summarily dismissed the petition as untimely, and the Idaho Supreme Court affirmed, ruling that Charboneau failed to file within a reasonable time after learning of the alleged evidence under the standard applicable to non-capital post-conviction petitions.

criminal lawprocedure

The case involved Ralph Naylor Farms challenging Latah County's Ordinance No. 258, which created a groundwater management overlay zone prohibiting mineral extraction and processing, after the County had opposed Naylor Farms' application for a groundwater right before the Idaho Department of Water Resources. Naylor Farms successfully obtained a district court ruling invalidating the ordinance as preempted by state authority over water quantity, then sought attorney fees and costs under Idaho Code section 12-117 on grounds that the County lacked a reasonable basis for its actions. The district court denied the fee request, and the Idaho Supreme Court affirmed that denial. The Court reasoned that although the ordinance exceeded county authority by regulating water quantity rather than quality, the County's adoption of it rested on a reasonable but erroneous interpretation of relevant statutes, including the Local Land Use Planning Act, so fees were not mandated.

business & regulatoryenvironmentproperty

This case involves a post-divorce child custody dispute in which father Kyle Nelson sought to modify an existing joint custody order to gain primary residential custody of the parties' three children after learning of mother Darline's plans to remarry and relocate with the children. The magistrate judge, after evidentiary hearings, denied the modification and kept primary custody with Darline while adjusting the holiday visitation schedule. On appeal, the Idaho Supreme Court affirmed the custody ruling, holding that the magistrate's decision was supported by substantial competent evidence regarding the children's best interests under Idaho Code § 32-717 and that the magistrate properly treated the motion as one for modification based on changed circumstances rather than a Rule 59 motion to alter or amend. The court also awarded attorney fees to Darline, finding the appeal frivolous because it amounted to an improper request to reweigh conflicting evidence and lacked any genuine factual or legal basis.

family law

This case involved a boundary dispute between neighboring landowners over a roughly one-acre strip of land. The Andersons built a fence on the disputed strip in 1977 based on an older survey and later asserted claims of adverse possession and boundary by agreement against Griffin, who held the deed to the strip. The district court granted partial summary judgment against the adverse possession claim, held a trial on the remaining issues, and quieted title in Griffin's favor after finding no boundary by agreement. The Idaho Supreme Court affirmed, holding that although the boundary was uncertain, the evidence showed the fence was erected primarily as a livestock barrier rather than pursuant to any express or implied agreement fixing it as the property line.

property

In Workman v. State, Kenneth Workman appealed the district court's summary dismissal of his petition for post-conviction relief after pleading guilty in 2001 to two counts of aggravated driving under the influence and being a persistent violator, resulting in two fixed life sentences. Workman claimed his plea was invalid because he was under the influence of antipsychotic medication, that he did not actually enter a guilty plea, and that he received ineffective assistance of counsel. The Idaho Supreme Court affirmed the dismissal, holding that Workman failed to raise a genuine issue of material fact on any claim, that the district court properly applied the Strickland test to the ineffective assistance allegations, and that appointment of counsel was not required because the claims were frivolous with no need for further investigation or 20 days' notice before summary dismissal.

criminal lawprocedure

The case involved Vondean Renee Karel, a licensed securities agent, whose license was suspended for six months by the Idaho Department of Finance after she refused to provide client lists and other records during an unannounced 2005 audit and investigation prompted by suspicions that an unregistered individual was conducting securities business. Karel appealed, arguing the Department lacked authority under Idaho Code section 30-14-411(d) to request those specific records and that the request was unreasonable or unconstitutionally vague. The Supreme Court of Idaho reviewed the agency record and affirmed the suspension, holding that the statute authorized reasonable audits without prior notice and that Karel was obligated to produce the client list as it related directly to the investigation, though personal bank records required a subpoena instead. The decision relied on the hearing officer's findings that Karel had or could produce the requested client information and on the broad statutory language permitting inspections in the public interest.

business & regulatoryprocedure