Idaho Supreme Court

The Court held that a district court lacks inherent equitable authority to require a defendant to post a surety bond securing a potential money judgment for an unsecured debt when the plaintiff has no present equitable interest in the defendant’s property.

The Idaho Supreme Court held that an executor controlling a corporation’s stock cannot bypass the corporation’s bylaws and statutory corporate procedures, even when the corporation is effectively a one-person corporation.

The Court held that domestic battery with traumatic injury was not a lesser included offense of attempted strangulation under either the statutory or pleading theory, and that Crombie preserved his objection to the instruction.

The Court held that Idaho continues to recognize defamation per se based on statements imputing unfitness to conduct a particular business, trade, or profession, but that the category requires a specific connection between the imputation and fitness for that occupation.

The Idaho Supreme Court affirmed summary judgment for the Division, holding that the Airport Zoning Act did not impose an individualized tort duty to the decedent because its regulatory powers served the public generally and were discretionary.

The Idaho Supreme Court affirmed the judgment declaring the purchase agreements for two condominium units invalid and unenforceable because they omitted material terms concerning the units’ construction, finishes, and specifications.

The Idaho Supreme Court affirmed the district court’s judgment, holding that the trial court did not err in finding Eric Posey was not a limited‑purpose public figure and that any error was harmless because the jury found actual malice.

The Idaho Supreme Court affirmed the district court’s denial of Al‑Mafrachi’s motion to suppress, holding that his probation‑waiver of Fourth Amendment rights extinguished any legitimate expectation of privacy in his backpack and thus barred standing to challenge the search. The Court also overruled State v.

The Idaho Supreme Court vacated the judgments against Pacific Life Insurance Company, holding that the insurer owed no duty to protect the plaintiff from purely economic loss and that the plaintiff failed to show the insurer granted the alleged agent apparent authority to market a third‑party investment product.

The Idaho Supreme Court reversed the district court’s summary dismissal of Steven Ennis’s post‑conviction relief petition and remanded for an evidentiary hearing, holding that counsel’s statements were not a binding concession and that genuine issues of material fact existed regarding ineffective assistance of counsel.

The Idaho Supreme Court affirmed the district court’s Third Amended Judgment, holding that post‑judgment interest accrues from the dates of both the Original Judgment (Oct. 15, 2021) and the Amended Judgment (Dec. 14, 2021), and that Snap! Mobile is entitled to attorney fees under Idaho Code §12‑121.

The Idaho Supreme Court affirmed the district court’s denial of a motion to suppress evidence obtained after an extraterritorial arrest, holding that the statutory violation of Idaho Code §67‑2337(2) did not rise to a constitutional level.

The Idaho Supreme Court affirmed the district court, holding that Jeff Conger lacked standing to enforce his option to purchase the Mountain Home property because the option remained part of his Chapter 7 bankruptcy estate.

The Idaho Supreme Court reversed the district court's judgment, vacated its decision, and remanded for further proceedings, holding that the lower court applied the wrong burden of proof to the parties' declaratory judgment claims. The Court also declined to award attorney fees to either party.

The Idaho Supreme Court held that grand theft of an automobile is a lesser‑included offense of armed robbery under the pleading theory, so Sedillo’s double‑jeopardy claim was viable.

The Idaho Supreme Court affirmed the district court’s summary‑judgment dismissal of Triple Crown Development and its intervenors’ business‑damages claim under Idaho Code §7‑711(2) and denied the State’s request for attorney fees on appeal.

The Idaho Supreme Court held that the district court possessed subject‑matter jurisdiction and authority under Idaho Criminal Rule 35 to amend the judgment of conviction to resolve an ambiguous oral sentence, but erred by conducting the resentencing hearing without the defendant present, vacating the amended judgment…

The Idaho Supreme Court reversed summary judgment for the county clerk, holding that quasi-judicial immunity does not bar an official-capacity action. It further held that the administrative fee schedule conflicted with the governing court rule and statutory fee limits, determined that Smith was overcharged by…

The Idaho Supreme Court remanded a Professional Conduct Board Hearing Committee recommendation denying Brian L. Webb's petition for reinstatement following his 2022 five-year suspension (two years withheld) for stipulated Idaho Rules of Professional Conduct violations arising from a sexual relationship with a client…

The Idaho Supreme Court affirmed summary judgment for the Roman Catholic Diocese of Boise and St. Mary's Catholic Church on a constructive fraud claim arising from the alleged 1968 sexual assault of nine-year-old Peter Leriget by Father Patrick O'Sullivan.

The Idaho Supreme Court reversed the district court’s summary judgment in part, holding that the Thaetes’ failure to serve their notice of appeal was not jurisdictional, that Dr. McIlraith’s expert testimony was admissible, and that summary judgment was improper as to Dr. Fry but proper as to St. Luke’s.

The Court affirmed the custody-modification judgment, holding that substantial and competent evidence supported the findings that no statutory domestic violence or child abuse occurred and that the increased parenting-time schedule served the child’s best interests.

The Idaho Supreme Court affirmed dismissal of HMI's trespass and nuisance claims, holding that the City possessed an express easement for the sewer line and a prescriptive easement for the disputed water line.

The Idaho Supreme Court reversed the district court’s affirmance of an in-kind award transferring half of the community-held corporate shares to the former wife. It held that the magistrate court could not compel the husband to act as a corporate fiduciary, improperly relied on corporate governance considerations, and…

The Idaho Supreme Court held that two minor land division applications were subject to judicial review under LLUPA because they were similar to subdivision applications and were authorized under LLUPA.

The Idaho Supreme Court affirmed the judgment quieting title to the Idaho property in Bobby Shaw. It held that Arizona's guardianship jurisdiction and later retroactive incapacity determination did not control the Idaho quiet-title action, and that the Idaho court properly denied a last-minute motion to add claims and…

The Idaho Supreme Court affirmed the district court's orders and judgment because Smith's appellate briefing failed to comply with the Idaho Appellate Rules, lacked cogent argument, and rendered his assignments of error too indefinite for review.

The Idaho Supreme Court affirmed the district court’s orders denying removal of the trustees, dismissing the beneficiaries’ partition claim, enforcing the PMT’s no-contest clause against Wayne, approving the in-kind trust distributions and property valuation, and awarding attorney fees.

The Idaho Supreme Court reversed the summary judgment determining that Parsons owned 50% of the property because Bedell presented evidence creating a genuine dispute about the parties' intended ownership interests, and the district court improperly weighed competing testimony.

The court affirmed summary judgment for the defendant in a medical malpractice action because the plaintiff’s out-of-area expert did not establish the foundation required to testify about the applicable community standard of care.

The Idaho Supreme Court affirmed the discovery sanctions striking the Hartmans’ liability experts because the Hartmans intentionally failed to disclose non-testifying local standard-of-care experts whose information contributed to the testifying experts’ opinions.

The court held that the Uniform LLC Act applied to the company and invalidated the operating agreement's waiver of judicial dissolution. It also held that the complaint pleaded only an oppression-based dissolution claim, so the district court erred by ordering dissolution on an unpleaded illegality theory.

The Idaho Court of Appeals vacated Hinkel’s conviction for attempted strangulation and remanded for a new trial, holding that the trial court abused its discretion by admitting police officers’ testimony as expert opinion without the required pre‑trial disclosure.

The Idaho Supreme Court affirmed the denial of Gutierrez’s request to continue sentencing until a psychosexual evaluation and polygraph were completed, holding that the district court acted within its discretion given counsel’s failure to arrange the evaluations and the absence of a guaranteed right to obtain them…

The Idaho Supreme Court held that an indigent parent in a private termination proceeding may have a due-process right to appointed counsel, including on appeal, but the determination must be made case by case after a hearing.

The Idaho Supreme Court affirmed the magistrate court’s decision allowing Jennifer to relocate with the parties’ children to Florida while awarding the parents joint legal and physical custody.

The Idaho Supreme Court affirmed the denial of Spirit Lake Cabins’ claim for a prescriptive easement over a private road crossing Inland Empire’s large timber property. The court held that the property was wild, unimproved, and unenclosed, creating a presumption that Spirit’s use was permissive, and that Spirit failed…

The court held that the defendant preserved his argument that statutory overdose immunity applied based on his actual condition. It reversed the dismissal of the possession and paraphernalia charges because the immunity statute unambiguously requires proof of an actual drug-related medical emergency, a need for…

The Idaho Supreme Court affirmed summary judgment against the Estate on its unjust-enrichment and Idaho Consumer Protection Act claims. It held that the unjust-enrichment theory merely repackaged the same alleged professional negligence and therefore was not an independent claim, and that the Estate lacked evidence of…

The Idaho Supreme Court affirmed the district court’s dismissal of Rilee Ann Lutz’s nonsummary contempt motion, holding that she failed to show probable cause and that the court had subject‑matter jurisdiction to hear the motion.