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

This case involved a dispute between Super Grade, Inc. (SGI) and the Idaho Department of Commerce and Labor over whether SGI should inherit a portion of Krick Equipment, Inc.'s (KEI) unemployment insurance experience rating and unpaid taxes. The Industrial Commission found that SGI had succeeded to 74.31 percent of KEI's excavation business due to substantially the same management and control plus continuity of operations, and ordered a partial transfer of the rating along with joint liability for the taxes under Idaho Code section 72-1351. The Idaho Supreme Court affirmed the Commission's decision after reviewing the record de novo, and also upheld the Department's liens on equipment purchased by SGI because the purchases were not made in good faith without prior lien searches as required by section 72-1362.

business & regulatorylabor & employmenttaxes

The case involved a dispute between the Chapins and the Lindens over whether the parties had formed an enforceable contract for the sale of a 40-acre parcel of property in Idaho following a foreclosure and the expiration of the Chapins' right of redemption. The Chapins sued for specific performance, claiming they had accepted the Lindens' counteroffer on the final day of negotiations, while the Lindens argued no agreement existed and any oral deal would violate the statute of frauds. The district court granted summary judgment to the Lindens, finding no meeting of the minds on material contract terms. On appeal, the Idaho Supreme Court affirmed, holding that the Chapins' requests for additional provisions on prepayment without penalty and partial deed releases were material terms that remained unresolved, preventing contract formation. The court did not reach issues of part performance or promissory estoppel because no agreement had been reached.

propertyprocedure

This case arose from a challenge to a long-term lease of only the garage portion of a condominium unit, which the original owners created before selling the property subject to the lease, with later owners like Thompson seeking to invalidate it under the condominium declaration. The district court ruled on summary judgment that the lease was void for violating the declaration's requirement that the unit and garage be conveyed or encumbered only as a complete whole. On appeal, the Idaho Supreme Court affirmed, reasoning that the declaration explicitly prohibited separating any part of the condominium and that a lease constitutes an encumbrance, making the partial lease invalid and not subject to a statute of limitations defense since it was void ab initio.

property

The case arose when sewage from a blocked City of Blackfoot sewer line flooded and damaged an apartment building owned by Dorea Enterprises, leading Dorea to sue the City for negligent operation of its sewer system. The district court granted summary judgment to the City, and the Idaho Supreme Court affirmed, holding that the City was immune from liability under the discretionary-function exception of the Idaho Tort Claims Act, Idaho Code § 6-904(1). The court applied a two-step analysis to determine that the City's annual sewer-line flushing policy was a planning-level decision involving budgetary, manpower, and policy considerations rather than a routine operational task. Because the decision qualified as discretionary, the City could not be sued even if negligence were shown. The court did not reach Dorea’s additional arguments concerning res ipsa loquitur or evidentiary rulings.

torts & liabilityprocedure

The case involved Lane Ranch Partnership challenging the City of Sun Valley's denial of three applications to rezone and subdivide a portion of its annexed property from open space to residential use, in conflict with an earlier annexation agreement that emphasized preserving open space. The district court granted summary judgment to the city and affirmed the denials on judicial review, concluding the agreement effectively barred rezoning without amendment. The Idaho Supreme Court reversed the summary judgment, vacated the order on judicial review, and remanded, reasoning that the agreement did not require amendment or prohibit the applications and that the city's denial relied on an incorrect interpretation of the agreement's limits.

propertybusiness & regulatory

This case involved a dispute over access to an easement on ranch land in Idaho stemming from a 1995 Stipulated Judgment between the parties' predecessors that granted Barnhill use of the Rock Creek Canyon Access Road across Steiner's Triangle Ranch property. After Steiner obstructed the road with a locked gate and trenches, Barnhill moved to hold him in contempt for violating the judgment. The Supreme Court of Idaho affirmed the district court's finding of contempt, its order enjoining Steiner from further interference with the easement, and its award of attorney fees to Barnhill. The court reasoned that the Stipulated Judgment bound successors in interest, that Steiner had denied access in violation of its terms, and that courts have authority under statute and common law to compel compliance with judgments through injunctions and other reasonable sanctions.

propertyprocedure

P.O. Ventures, Inc. sought to enforce a land sale contract against the Loucks Family Irrevocable Trust and its trustee George Loucks for a 14.66-acre parcel intended for inclusion in a residential subdivision. After negotiations on November 6, 2004, the parties signed a handwritten addendum specifying a $900,000 purchase price, down payment, closing date, and other terms. When Loucks refused to sign a subsequent typed agreement, POV sued for specific performance based on the signed addendum. The district court granted summary judgment to POV, concluding that the addendum contained all essential terms of a valid land sale contract, and the Idaho Supreme Court affirmed this decision along with the award of attorney fees and costs under Idaho Code section 12-120(3) for prevailing in a commercial transaction.

propertybusiness & regulatoryprocedure

Homeowners Steve and Paula Fritts sued their general contractor Liddle & Moeller Construction and its officers over disputes arising from the building of a custom home, asserting twenty-five claims including breach of contract, unjust enrichment, negligence, violation of the Idaho Consumer Protection Act, and conversion; the contractor counterclaimed for damages and attorney fees. After a court trial, the district court found that the unsigned estimate did not form a complete contract with all material terms, that both parties had received fair value under their informal agreement, and that neither side was entitled to relief, but it awarded attorney fees to the contractor as the prevailing party in a commercial transaction under Idaho Code § 12-120(3). The homeowners filed multiple untimely or unperfected motions for a new trial or to amend the judgment, all of which the district court denied. On appeal without a trial transcript, the Idaho Supreme Court affirmed the denial of post-trial relief and the fee award, holding that the absence of a record required the conclusion that the trial court's findings were supported by the evidence, and it further awarded appellate fees against the homeowners' attorney under I.A.R. 11.1 for pursuing an appeal lacking factual or legal grounding.

business & regulatorypropertyprocedure

James Hairston, convicted of two counts of first-degree murder and robbery with death sentences imposed, appealed the dismissal of his successive petitions for post-conviction relief, a writ of habeas corpus, and a motion to correct his illegal sentence. The Idaho Supreme Court considered the State's motion to dismiss these consolidated appeals under Idaho Code § 19-2719, which restricts capital defendants to one timely post-conviction petition and permits successive petitions only under narrow exceptions. The court granted the motion to dismiss, concluding that Hairston's claims—including ineffective assistance of counsel and a Ring v. Arizona challenge—fell outside those exceptions, that Rule 35 could not be used to circumvent the statute, and that jurisdictional limits precluded review of related motions to disqualify the district judge. The appeals were therefore dismissed for lack of jurisdiction.

criminal lawprocedure

The case involved Mary Jo Stolle's claim for worker's compensation benefits after she alleged she slipped on ice and fell while working as a driver for Christine Bennett's limousine service on December 18, 2003. Bennett disputed the claim, testifying that Stolle was no longer employed on that date and that the incident never occurred. The Industrial Commission denied benefits after a referee found Stolle not credible based on conflicting testimony and evidence. On appeal, the Idaho Supreme Court affirmed the denial, holding that substantial competent evidence supported the Commission's credibility determinations and findings of fact, and that the Commission properly denied a post-hearing deposition motion under procedural rules. The Court also awarded attorney fees against Stolle's counsel for pursuing a frivolous appeal that sought only to reweigh evidence.

labor & employmentprocedure

This case involved a challenge by senior water rights holders (American Falls Reservoir District and others) to the facial constitutionality of Idaho's Conjunctive Management Rules, which govern how the Department of Water Resources responds to delivery calls between senior surface water users and junior groundwater users in hydraulically connected sources. The district court ruled the Rules unconstitutional for lacking specific procedural elements required under Idaho's prior appropriation doctrine, such as defined burdens of proof, timelines, and objective injury standards. On appeal, the Idaho Supreme Court reversed, holding that the Rules are not facially unconstitutional because Rule 20.02 incorporates existing Idaho law on these matters, and the Rules properly account for partial decrees and carryover storage water without violating constitutional requirements. The court also affirmed the district court's revocation of a late intervention motion by the City of Pocatello as within its discretion. The dispute centered on whether the Director's administration of interconnected water rights complied with Article XV of the Idaho Constitution and statutory prior appropriation principles.

propertyenvironmentprocedurebusiness & regulatory

This case involved an appeal by William Jenkins from the denial of his motion to suppress evidence obtained during a warrantless police entry into his garage, where officers had responded to a reported battery and DUI investigation based on a victim's description. The magistrate judge and district court upheld the stop as a valid Terry stop, but the Court of Appeals reversed, finding no entitlement to follow Jenkins inside. The Idaho Supreme Court affirmed the denial of suppression, holding that officers had probable cause to arrest Jenkins in a public place (his driveway) based on the victim's statements, vehicle match, and timing, and under United States v. Santana, they could pursue him into the garage to complete the arrest without a warrant. The court emphasized that the Fourth Amendment protections did not prevent such a hot pursuit initiated in public, rendering the evidence admissible.

criminal lawprocedurecivil rights

This case involved a lawsuit by Carolyn Finholt against Jason Cresto and his business, Fairway Lawns, seeking damages for injuries from a 2002 car accident. Finholt claimed Cresto was liable under the doctrine of respondeat superior because the driver who caused the crash, Jacob Albrethsen, was an employee acting within the scope of his employment at the time. The district court granted summary judgment to Cresto, finding no genuine issue of material fact that Albrethsen had finished his work assignments and was driving to a personal lunch when the collision occurred. On appeal, the Idaho Supreme Court affirmed, holding that the coming-and-going rule applied, that neither the special-errand nor traveling-employee exceptions were met on these facts, and that Albrethsen's travel was therefore outside the course and scope of employment.

torts & liabilityprocedure

This case involves a divorce between James and Sally Stewart, where the primary disputes centered on the division of community property—including the valuation of James's 45% interest in a dermatology professional corporation—and the award of spousal maintenance. The magistrate court characterized $210,747 in professional goodwill as community property separate from James's personal skills, awarded Sally an unequal share of the community assets totaling over $788,000, and ordered maintenance of $5,166 per month for twelve years, later adjusting for a calculation error but maintaining the overall award. The Idaho Supreme Court reviewed the magistrate's findings independently, applying an abuse of discretion standard, and concluded that the goodwill valuation and property division were supported by substantial competent evidence while the maintenance award was within the trial court's discretion after considering Sally's health, work history, and financial needs. The Court affirmed the community property characterization and support determination, emphasizing that issues not preserved below could not be raised on appeal.

family lawproperty