Justia Criminal Law Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil

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This appeal came from a district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” Picatti contended Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers (I.C. § 18-705), and aggravated battery on law enforcement. Ultimately, Picatti was convicted, accepting a plea agreement to disturbing the peace and failure to obey a traffic sign. Two years later, Picatti brought his 42 U.S.C. 1983 suit, claiming he was deprived of his rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the deputies, holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. The Idaho Supreme Court affirmed summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

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Due to a failed breath alcohol test and multiple convictions for driving under the influence, the Idaho Transportation Department permanently suspended Bruce Edwards’ driving privileges to operate a commercial motor vehicle. The district court affirmed the Department’s order and Edwards appealed. After review of the Department’s order and the circumstances leading to the suspension, the Idaho Supreme Court affirm the district court’s judgment and the Department’s lifetime disqualification of Edwards’ commercial motor vehicle driving privileges. View "Edwards v. Transportation Dept" on Justia Law

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This appeal arose from the district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In July 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” The factual background from that point was heavily disputed. Picatti alleged Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers and aggravated battery on law enforcement. At the end of his preliminary hearing, Picatti was bound over. Prior to trial, Picatti accepted a plea agreement in which he pleaded guilty to disturbing the peace for “failing to obey a traffic sign and driving into a restricted pedestrian area.” The court entered a judgment of conviction, which was not appealed, overturned, or expunged. Two years later, Picatti brought a 42 U.S.C. section 1983 suit against his arresting deputies, claiming deprivations of his protected rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the defending deputies holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. Picatti timely appealed. The Idaho Supreme Court affirmed the order granting summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated the summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

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Mother Jane Doe appealed a magistrate court’s termination of her parental rights to her child T.G.E. At the time she gave birth, Mother had pending felony drug charges and an active warrant for her arrest; the child’s umbilical cord tested positive for methamphetamine at birth. Following a termination hearing, the magistrate court found termination proper based on neglect and entered an order to that effect on December 8, 2017 (the Order). However, in a subsequent decree (the Decree) issued on December 15, 2017, the magistrate court stated Mother’s parental rights were being terminated based on abandonment. The court also terminated Father’s parental rights however, Father had voluntarily relinquished his parental rights and was not a party to this appeal. On appeal, both Mother and the Department raised procedural issues relating to the conflicting Order and Decree. Subsequently, the Idaho Supreme Court remanded the case for entry of a new judgment terminating Mother and Father’s rights to Child, and stated the Order would constitute the findings of fact and conclusions of law. Mother appealed, contenting the magistrate court erred when it terminated Mother’s parental rights. Finding no reversible error, the Supreme Court affirmed the ultimate termination. View "DHW v. Jane Doe" on Justia Law

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Saint Alphonsus Regional Medical Center, Inc. (“Saint Alphonsus”) appealed the grant of summary judgment in favor of Ada County Sheriff, Gary Raney, in his official capacity; Ada County; and the Board of Ada County Commissioners, (collectively, “Ada County”). The district court ruled as a matter of law that Ada County was not obligated to pay for an inmate’s (“Patient”) entire hospitalization where the State sought a release from custody during the hospitalization so the inmate could receive medical treatment. The district court ruled that Ada County’s obligation to pay for the hospitalization stopped once a release order was entered. The Idaho Supreme Court held the district court erred in its interpretation of Idaho Code sections 20-605 and 20-612 and vacated the judgment entered in favor of Ada County. View "St. Al's RMC v. Ada Co Sheriff" on Justia Law

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This was an appeal of a judgment against a bail bondsman who revoked a bail bond for an illegal alien at the request of an agent of United States Immigration and Customs Enforcement. The district court awarded damages in the amount of the bail bond premiums, and the appellants contended on appeal that they were entitled to additional damages. The Supreme Court found no reversible error in the district court's judgment and affirmed. View "Garcia v. Absolute Bail Bonds" on Justia Law

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In 2006, John Doe (“Father”) and Mother were the parents of three minor daughters who were approximately 5, 6, and 7 years of age. A federal grand jury in Idaho issued an indictment charging Father with hiring someone from out of state to kill Mother. The indictment alleged that Father had agreed to pay that person $10,000. A jury found Father guilty, and the federal court sentenced him to 120 months in the custody of the United States Bureau of Prisons and three years of supervision following his release from prison. The federal court also sentenced him to a fine of $17,500. Following Father’s arrest and incarceration, Mother had sole custody of their three minor daughters. By 2013, the girls were 12, 13 and 14. Mother was having psychological issues and tried to take her own life; the eldest daughter also had attempted suicide. The State intervened and filed for protection under the Child Protective Act. The Department of Health and Welfare recommended the girls remain in shelter care due to an unstable home environment; Father wanted the girls placed with his adult son in Arizona. Ultimately, termination of Father's parental rights was recommended and granted. Father appealed, arguing the evidence of abandonment and neglect was insufficient to support termination of parental rights. Finding no reversible error in this respect, the Supreme Court affirmed the termination of Father's parental rights. View "Idaho Dept. of Health & Welfare v. John Doe (2016-09)" on Justia Law

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Plaintiff-appellant Barry Searcy was an inmate in the custody of the Idaho Department of Correction (IDOC). In 2011, he filed a civil complaint naming as defendants the Idaho State Board of Correction, IDOC, and various individual defendants in their official capacities (collectively “the Board”). Searcy’s complaint alleged that the Board illegally charged inmates fees for: (1) commissary goods; (2) telephone calls; (3) photocopying; (4) medical service co-pays; and (5) hobby supplies. The Legislature had not provided express statutory authorization for any of these fees at the time that Searcy brought this action. Instead, the fees were imposed based upon IDOC policy or Standard Operating Procedures (SOPs). The Board moved for summary judgment in all claims, and the district court ultimately granted the Board's motion. Searcy appealed, and his claims “solely challenging the district court’s grant of summary judgment as to Count I” (alleging that raising revenue through the disputed fees exceeded the Board’s rulemaking authority under Idaho Code section 20-212 and caused a wrongful forfeiture of property in violation of Idaho Code section 18-314) were heard by the Court of Appeals. In a split decision, the Court of Appeals affirmed. Searcy petitioned for review, which the Supreme Court granted. After review, the Court determined that the fees at issue here were not unconstitutional fees. As such, it affirmed the Court of Appeals' judgment. View "Searcy v. Idaho Bd of Correction" on Justia Law

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At the heart of this appeal was a dispute about the duration of an administrative suspension of an Idaho driver’s license. Respondent Susan Warner was convicted in Idaho of driving under the influence of alcohol (DUI). Two years later, she was convicted in Montana on another DUI charge. Upon receiving notice of the Montana conviction, the Idaho Department of Transportation administratively suspended Warner’s driver’s license for a period of one year. Warner challenged the duration of the suspension, arguing that because the Montana conviction was not for a “second DUI” the maximum allowed suspension was thirty days. The Department rejected Warner’s challenge, but on judicial review, the district court reduced the suspension from one year to thirty days. The Department appealed. Finding that the district court erred in reducing the suspension; "it was not error for the Department to apply Idaho Code section 18-8005(4)(e) to impose an administrative suspension for one year based on the Montana DUI being a second rather than a first DUI conviction." The Court vacated the district court's decision and remanded for further proceedings. View "Warner v. Idaho Transportation Dept" on Justia Law

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In 2012, Rayland Brown was charged by indictment with the felony crime of forcible sexual penetration by use of a foreign object. On the second day of Brown’s jury trial, he and the State agreed to a written plea agreement. One of the provisions of the plea agreement was that the charge would be amended to felony domestic battery. On the same date, the State filed an information charging the crime of felony domestic battery, and Brown pled guilty to that charge. The district court sentenced Brown, and in accordance with the plea agreement the court retained jurisdiction for 365 days. A year later, the court entered an order relinquishing jurisdiction, which resulted in Brown being required to serve a prison sentence of at least fifteen years and up to twenty years, with credit for 483 days already served. Brown filed a motion for reconsideration, and the court reduced the mandatory portion of the prison sentence from fifteen years to eleven years. Brown then filed this civil action seeking post-conviction relief on the ground that he received ineffective assistance of counsel in his criminal case. The district court interpreted the alleged ineffective assistance as being that his counsel advised him that he would receive probation after the period of retained jurisdiction and failed to object to the court’s alleged deviation from the plea agreement. The district court dismissed the petition for post-conviction relief because the court in the underlying case did not deviate from the plea agreement and the plea agreement, which Brown signed, notified him that he may not receive probation because it expressly provided that “[a]t the end of the period of retained jurisdiction, the court would be free to exercise or relinquish jurisdiction in its discretion.” Brown then appealed, challenging whether the court in his criminal case had subject-matter jurisdiction. The Supreme Court concluded Brown could not raise that issue for the first time on appeal in this civil action, and affirmed the judgment in this case. View "Brown v. Idaho" on Justia Law