Idaho Criminal Defense Blog : Boise Idaho Criminal Lawyer & Attorney : Chuck Peterson Law Firm : Civil Rights, Trial, Felonies, Assaut, DUI : Boise, Idaho Falls, Pocatello, Idaho

 If you have been injured by an Idaho state, county, or city employee and you want to bring a civil lawsuit for damages, you MUST file a notice of tort claim before you can bring a lawsuit to recover for your injuries. Even if the potential defendant is not an employee - you still must file the notice of tort claim to have a chance to recover money damages from injuries or death that resulted from a government employee or agent's negligence.  The law in Idaho requires that the tort claims notice must be filed WITHIN 180 days of the date of your injuries. Again, if you do not file the notice of tort claims within that time, you HAVE NO RIGHT TO SUE.  

If your case involves any of the following types of entities or their employees or agents, you will need to file a Tort Claims Notice before you can bring suit:

• State office or department;
• State agency, authority, commission or board;
• State hospital;
• State college or university; 
• County;
• City;
• Municipal Corporation;
• Health District;
• School District;
• Irrigation District;
• Special Improvement or Taxing District;
• Hospital or Nursing Home established by a County or City;
• Any other State or local governmental entity

There is no "form" that is required for your tort claims notice, but it must include certain information including the conduct and circumstances which brought about the injury; the nature of the injury or damage; the time and place the injury or damage occurred; the names of all persons involved; the amount of damages claimed; the residence of the claimant. 

This is a very important requirement that you may not get right if you rely on your own understanding of the law. If you get this one wrong - you have no case, so get some help. Call a lawyer who has experience with this. I have had to tell that potential client that his right to sue under state law was gone because he had failed to file a proper notice of tort claim, and that was a conversation I will never forget. So get some help.

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This past month has resulted in at least two car-bicycle collisions, each with its own tragic consequence. Several weeks ago, Boise Police Officer Chris Cowling was struck by a driver in Caldwell. Officer Cowling was the victim of a hit and run that has left him hospitalized and facing a long recovery. A little more than a week ago another Boise bicycle rider was struck by a car making a left turn. That driver was cited for an infraction. Some might say that this year has been kinder to bicycle riders than last year - when three riders were killed. Here are three things you need to know if you have been hit by an Idaho driver while riding your bike:

First - you have the right to collect your damages from the driver of a vehicle that strikes you while riding your bike, but bicycle riders have obligations and duties to others on the road too. Those duties include your duty to follow the traffic laws. If you fail to follow those laws and are struck as a result, your own negligence may preclude a full recovery.

Second - like any other civil action in Idaho, there are time limitations on your right to recover. Generally in Idaho a civil action for negligence requires that you commence your suit in two years. The actual statute may give you more time if you were a minor at the time.

Third - you need to keep good track of the records that demonstrate your damages. Keep copies of those medical bills and pharmacy records so that you can demonstrate your actual damages. The same is true of your lost time at work. And keep a simple log of your recovery - who you saw, what physical therapy or medical visit occurred and when, and how you felt.

Most importantly, take time to heal. We ride because we love being out there on the road - so get back in shape and back out with friends riding in Boise. 

I was reminded how dangerous riding bikes in Boise can be last night when a car decided to play "chicken" with me as I was riding in Columbia Village. My iPhone camera did not capture that blue sedan as it bore down on me - and I chased the driver back to Federal Way to get the license number, but never quite got there. Here's hoping that idiot does not strike some rider - and here's hoping Chris Cowling and other cyclists hit recently on the roads have a full recovery.

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When a police officer goes too far – and uses excessive force – he can be held accountable for the harm he causes. Police officers have a tough job. We rely on them to keep us safe, and most of the time an officer uses force it is justified. Still, if you have been harmed by the actions of a police officer, you may have a case. The officer and his or her agency may be responsible for your damages.

Holding a law enforcement officer accountable is not an easy assignment. The evidence must make it clear that the force used was unreasonable or unnecessary. For example, if an officer used a baton or stun gun on someone who was simply arguing whether he or she had been speeding, a case might be made that the officer had used excessive force.

Here are three things to keep in mind about your potential excessive force claim:

First, a law enforcement officer may use force that is necessary under the circumstances presented. So not every use of force will result in a case.
Second, juries want to believe that law enforcement officers “did the right thing” when confronted with a tough situation. This means that you will likely start at a disadvantage when it comes to credibility, so your choice of a lawyer to handle the case is critical to your possible recovery.
Finally, there are procedural hurdles designed or intended to keep you out of court and to limit your recovery. Do not wait to contact an attorney and review your rights as the passage of time may destroy any opportunity you have to recover.

To safeguard your rights, your lawyers need to build your case expecting to go to trial. This means that we will help you safeguard evidence, document your medical treatment, account for lost wages and employment, and identify and interview witnesses.

If you or a family member have been injured or killed as the result of a confrontation with the police, call us for a free consultation.

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Have you noticed how many attorney websites are all about the lawyer and pay no attention to the information that people charged with criminal matters are looking for? Most lawyer websites scream: "Hire me! Do it now! You might go to prison if you don't act within the next hour! Call me now!"

I hate those websites! Instead of providing information, the lawyers using the sites try to scare you into hiring them based on emotion, not information. The truth is you might not even need an attorney to handle your case. So before you sign that retainer agreement, get informed!

This blog is different. There is a ton of free information here for you to review based on your needs. Have a DUI case? Check out the DUI section of the Topics. Have a question about how to value a personal injury or wrongful death case? Look at the Civil Practice section.

The Topics section can lead you to information that you can use to help you become informed on whatever area of law you are interested in. Well, not every area - this blog is really about criminal defense, civil rights and civil trials. With over thirty years of experience in those areas, my goal is to help you become better informed!

And what if the issue you have is not listed in the Topics? Send me a question and I will get back to you. We promise to get you information - then you can make a great decision about whether you need a lawyer and which lawyer you want to hire.

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In the past six weeks, Courtney and I have tried two criminal cases in Ada County.  The first case charged vehicular manslaughter - two felony counts. Last week we tried a case that charged aggravated assault with a deadly weapon and injury to jails (both felonies), as well as misdemeanor counts of false imprisonment, battery and destruction of a communication device (a cell phone). We picked juries in each case, and had the benefit of a jury consultant on the manslaughter case. As we have earlier reported in this blog, the jury in the manslaughter found our client not guilty of the felonies. Last week the jury in the aggravated assault case said not guilty as to the disputed charges (but guilty of the battery in the face of a self-defense claim), but guilty of the two misdemeanors our client had admitted committing.

So what did we learn?

In each case we approached the process of jury selection as one of inclusion, not exclusion. This is a Trial Lawyers College ("TLC") thing. Getting rid of folks from the panel is always tricky, even with a jury consultant, because lawyers are usually looking to "craft" a panel of jurors who are more likely to go their way than the way of their opponent. The problem with that approach is that we are not as "crafty" as we believe. So the TLC approach is different - start instead with your biggest fear in the case and work your way through this with the potential jurors. So we start by admitting we have potential problem areas in the case, and ask the jurors if they are going to be able to remain open to the balance of the case even knowing about the problems. We try to include folks by talking about the warts, and then getting the juror to open up about his or her feelings. Sounds all "touchy-feely" doesn't it? I think it works.  

Let's consider the problem posed by a recent client's admissions that he had hit his girlfriend. Guy hitting girl equals problem. Growing up as men in society, we hear repeatedly a universal truths: "men don't hit girls." Period. Ever. So when we have a client who has done that - struck a woman - you need to talk about it early and often with potential jurors because it goes against this deep seated belief we have as men. We talk it out and see if the jurors can get past it and get to the issue that they must decide.

Of course all this talk about inclusion is in some ways just talk. At the end of the day the lawyer has to decide which jurors represent the biggest obstacle to a fair trial based on their answers and their experience.  With thousands of dollars paid to jury consultants, I have never forgotten the words of the Hat - "experience trumps everything else." He is right about that. Any juror who has had an experience with domestic violence cannot help but have a predisposition one way or the other in a domestic violence case. If you can get them talking they will tell you whether they can serve fairly. 

But back to the question - what did we learn?

First, we learned that the TLC process works to identify the potential trouble spots with jurors. Spence says that if you are willing to show the jurors your weakness (area of concern) they will talk about their own fears. I think that is exactly what happened in both cases. In the manslaughter case I talked about my fear that people might immediately conclude a person with poor vision has no place driving on the road. The jurors opened up about that weakness and talked through their perceptions. From that we made some inroads into building a relationship with the jurors. They understood that they could look to us for the answers in the case, and they could trust us to be honest about the evidence.

The second thing we learned was that having the jury consultant is a huge help but you can get past the benefit of that expertise by taking more preparation time for voir dire.  Given my choices, I would always enlist the aid of a consultant, but even the best consultant cannot pick your jury. The lawyer is ultimately going to have to make the tough call about who should stay and who should go. The consultant I use always asks me what ONE question I would ask if I could only ask one. From that one question we need to be able to expose our concern to the jury and get them talking about how they feel.

Getting ready for trial? Worried about picking that jury? Get a copy of Gerry Spence's book "Win Your Case" and read the chapter on jury selection. That is a great starting point for the TLC method that consistently works for us.

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 Is a convenience store that sells alcohol to a minor liable for injuries caused when the minor, drunk and driving, injures or kills another? The answer is likely "yes."  I had an interesting call about such a fact pattern and did a little research to find a similar fact pattern, and there are plenty of them out there.

Generally, a store that sells alcohol has a duty to check identification of the buyer. If the store breaches that duty by failing to check, and sells alcohol to a minor, there is potential liability for the seller. If the seller routinely fails to check identification that liability could include additional damages to someone injured by the purchaser. 

In one case I know of, a minor who purchased alcohol from a convenience store collided with another car, resulting in his death.  His survivors brought a lawsuit against the store, and showed that the store (which videotaped sales) had a practice of selling beer to minors without checking for identification. The case settled because it was clear that the duty owed to the public had been breached, resulting in the wrongful death of the minor. 

The answer to this problem should be simple enough - store employees simply need to insure that they sell alcohol only to adults.

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 This week I had to write that "sorry, but I cannot take your civil rights case" letter to a man who had been badly assaulted in prison.  In Idaho over the past year there have been a number of lawsuits filed by prisoners and lawyers on their behalf for damages they received when the prison failed to protect them from other inmates.  Many of the cases have value - and for lawyers representing folks in this setting, value is a critical part of decision-making process.  How do we place a "value" - money value - on someone's case?

First, I look at the circumstances that lead to the injury. In Idaho a person may recover for specific economic and medical losses as well as "general damages." The general damages component refers to the sum of money that will compensate you for your pain and suffering - that is in addition to out of pocket lost earnings or medical expenses. A person in prison will likely have very limited economic loss when compared to a non-prisoner plaintiff in a personal injury or wrongful death lawsuit. They may have the loss of future earnings, but those prison jobs do not pay much while an inmate is serving time. The same is usually true of the medical damages. Medical treatment may have been provided by the State as part of its duties to an inmate.  

General damages are limited by Idaho law. The number today is approximately $270,000 (adjusted for inflation).  Our legislators apparently do not trust Idaho juries enough to let them decide how much money to award in a damages case. They have artificially set a cap or limit, in the wild eyed hope that our insurance premiums would go down.  Check out your last three years insurance cost - has it gone down? I don't think so!  

Next, I assess the likelihood that the case can be settled without a trial. Most cases do not get tried, but they often settle on the courthouse steps. That means that the lawyer has to spend the time to get ready and pay the costs of hiring expert witnesses, conducting discovery and investigating the clients' claims. 

Finally, I get real. You need to do the same thing with your case.  

Ask yourself what you would award if you were a juror. A case I recently rejected contained this assessment by the person who wanted me to be his lawyer:

"There is a similar case filed in Boise in which there are 30 plaintiffs who have sued for $120 million, so my share should be $4 million."

Probably not. It is a mistake to assume that your case will have a particular value based on what others have received, or more importantly - what others have sued for. That $120 million number in my example is meaningless.  If each of the 30 plaintiffs received the maximum $270,000 for general damages, the total value of the 30 cases excluding special damages (lost earnings, medical costs, future lost earnings and medical costs) would be $8.1 million. And that assumes everyone's case gets the same amount, which is also not likely. 

The real value of your case is seldom as high as you want to believe. Thirty years of doing this has taught me that it is usually less than I expect it to be. 

Trying to evaluate what your damages are in a potential civil case? Whether the case is for personal injury, wrongful death, civil rights violations or fraud, your damages are very individual and the value of the case will likely be difficult to predict.  You need to take into consideration a lot of individual factors - including where the case will be tried (Boise or Bonners Ferry) and who will be trying it. 

Don't get swayed by TV lawyers who proudly claim that they got "$300,000 for John's auto accident injuries."  Your case may be nothing like "John's" and that lawyer may have taken $300,000 for a $3,000,000 case.  

Most importantly - shop around. You have time. Don't be afraid to make more than "one call," and do not hesitate to talk to many lawyers about the facts of your case.  Finding the right lawyer is too important to do otherwise.

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I am in a funk. Two weeks in a trial and now I need to decompress, so I am back to reading a book I bought by John Maxwell on communication. Actually it is not about communication - it is about connecting. As lawyers we need to connect with jurors; with clients, and with our family members. That connection comes at a price - in a way - but the result of connecting is a wonderful and more meaningful life.

So while I recoup, regroup and get back to running too many miles and swimming too many laps - I really urge you to pick up a copy of Maxwell's book and dig in. It is easy reading, even for lawyers.

Let me just share one idea from the book. Maxwell says that before we can get what we want, we have to meet the needs of the other person. So with a client for example, we have to identify their needs and meet them first if we are to really interact with them and advance their interests. Same goes for our children, wives, husbands and - well - you get the picture.

To win at trial we need to do more than talk. We need to connect. We have to identify the jury's needs and figure out a way to meet their needs. For example - jurors often express a need to "do the right thing" while also "protecting the community." As trial lawyers we have to develop a case that allows them to feel good about both, so that they can help us. We need to connect.

So grab a copy and get going.

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 Almost forgot about this one - Charles Hartman - pled guilty to sexual abuse of a minor in 2007. On January 13th a jury awarded his victim $1.9 million. Boise lawyer Walt Bithell represented the victim, who was 16 at the time she was molested. Speaking about the role of the civil case:

"The civil case is designed to do what the criminal system won't do - try to make the family whole. You cannot believe the impact on the victim, and the victim's family," said Bithell, who said in 40 years of practicing law he can remember only one other time when a family pursued a civil judgment in a sex abuse case.

The unanimous jury awarded $1 million in punitive damages, and the balance ($921,000) to cover general damages, counseling and the damage to the family relationships.  Although most offenders go to prison and have no money to provide for their victims - that is not always the case.  Hartman reportedly has business and real estate that might provide a way to recover the verdict.

So what does this say about the state of justice in Idaho? First, it is possible to win a jury verdict in a civil case that seeks compensation for crime victims. Bithell is a legend here - great trial lawyer and a great man. And Walt had the things you need to win: liability AND damages. 

Second, those "run away" verdicts are urban (and country) myths! The jury awarded $1.9 million - not $99 million - like those insurance companies would have us believe. They and the legislature have limited the amount of money a victim can recover in most civil cases supposedly because Idaho juries are not "reasoned" (OK - insert the word  "smart" if you dare) enough to sort out real damages from the imagined. Nonsense. Idaho juries, and juries in virtually every courtroom across the land, have a better grasp on what is real and what is imagined than do the insurance fat cats. Think AIG would get those monster bonuses if a group of 12 jurors got to decide?

Third, to win a case like this you have to be willing to try the case. That goes for the client, family and lawyers. Defendants are not going to hand over $1.9 million without a fight, so put on the gloves and get to it. You need a gladiator for your case, and the will to see it through. And trust the jury to get to the truth.

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 When I was at the Trial Lawyers College I met Daniel Rodriguez - a mild mannered civil rights lawyer from Bakersfield CA. He showed me there that he was simply one of the greatest story tellers in the class and undoubtedly one of the great trial lawyers in the country. He has a home town style that quickly captivates those around him. 

He also just won the biggest verdict in California history for a drunk driving case - $31 million. 

So how did he do it? Here are a couple things that made his case so compelling: 

First - his clients had real damages. His primary client had brain damage and will need constant care for the rest of her life. So there were huge sums of money that will be needed to keep 19-year old Rosie Landros alive. Real damages make a real difference. So often we have potential cases where people are hurt, but seldom are they as severely hurt as the victim here.

Second - there was real liability. The driver of the other car had pled guilty to driving under the influence of alcohol (DUI). When liability is established, the only question is how much the victim is entitled to for damages and there is no issue of contributory negligence. 

Third - THERE ARE NO LIMITS FOR NONECONOMIC DAMAGES IN CALIFORNIA - or Wyoming, or Montana, or Texas or a whole bunch of other states. So pain and suffering has real value in those states. In Idaho the insurance companies convinced our state legislature that juries award too much money for pain and suffering, so WE HAVE A $250,000 limit or cap on noneconomic loss. Our pain is not worth as much as the pain suffered in neighboring states. 

And those same legislators clamor for tort reform while taking money from those insurance companies and their lackies.  

Here's an idea - let's throw them all out of office and start over. Then we the people can restore to us the same rights we would have if we were injured in a neighboring state.

Want to read more about this case? Check out the newspaper account here. And congrats Daniel. From a class of pretty good lawyers at Trial Lawyers College, you again showed us that you are the King!

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 In another one of those confusing 9th Circuit fraud decisions - the Court of Appeals has upheld the convictions and sentences of three men who summoned the likes of Charles Ponzi and swindled 1700 investors out of $40 million. In US v. Treadwell the Court upheld an instruction  that “intent to defraud is an intent to deceive or cheat,” and that “a defendant’s belief that the victims of the fraud will be paid in the future or will sustain no economic loss is no defense to the crime.”

The Court goes on to draw an analogy to embezzlement. It is not a defense to embezzling money from your employer that you intended on returning the money to him someday - even if you honestly believed you could, with interest! That makes sense to me because fraud is simply theft - if you get the money by lying it is not a defense that you may someday give the money back, or the investor may someday get the investment back. Bernie Madoff's investors got money back, from other investor money!

And if someone was to sweet talk my wife into "giving" them my MacBook Air on the premise that we would get two new ones back in a few months, I wouldn't care whether he or she had the good faith belief that they could get me a 100% return on my bride's "investment." My computer would be gone - just like the investor's $40 million. 

Look at the following language - it pulls together the key stuff here:

"According to the federal wire fraud statute, 18 U.S.C. § 1343, any person who “having devised or intending to devise any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises, transmits or causes to be trans- mitted by means of wire, radio, or television communication in interstate or foreign commerce, any writings, signs, signals, pictures, or sounds for the purpose of executing such scheme or artifice,” is guilty of wire fraud. Conviction under § 1343 means a defendant must have intended “to defraud” his victim. See United States v. Oren, 893 F.2d 1057, 1061 (9th Cir. 1990). “To defraud” under § 1343 encompasses “any scheme to deprive another of money or property by means of false or fraudulent pretenses, representations, or promises.” Carpenter v. United States, 484 U.S. 19, 27 (1987); see also United States v. Ciccone, 219 F.3d 1078, 1082 (9th Cir. 2000) (“[T]he offense’s specific intent element . . . require[s] proof of intent to deprive the victim of money or property.”). It means to “wrong[ ] one in his property rights by dishonest methods or schemes, and usually signif[ies] the deprivation of something of value by trick, deceit, chicane or overreaching.” Carpenter, 484 U.S. at 27 (internal quotation marks omitted)"

It's the scheme that is the key - if you get the money by lying and scheming the law will be at your door. Or maybe - it will be some lawyer in a nice suit looking to collect back that "investor" money from you in a civil suit. Either way, this case is fair warning that the scheme imposes liability - both civil and criminal. 

Have a question about an investment "opportunity" that seems too good to be true? Get some advice before you give away the farm.

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 In the past week or so, two men were killed while riding their bikes in Boise.  Tonight, a third cyclist was struck by a car near Fairview and Amber streets.  How does it happen that drivers continue to injure and kill persons riding their bikes lawfully, on Boise streets? I have to confess that I ride on Boise streets almost every day and it can be crazy out there, but the simple reason this happens is that too many drivers do not pay attention. They sometimes "brush off" the rider without really thinking how easy it is to kill a rider.

So here is the legal standard drivers - the bike rider ALWAYS has the right of way. Always - as in every time. 

I hear drivers complain that bicycles sometimes slow them down, ride in "their" lanes and refuse to move over. Seriously - there is never an excuse for hitting a bicyclist because you are unhappy about having to "share" the road. Bicycles may be slow and they may "infringe" on "your" road but it is their road too. If you drive negligently, and injure or kill someone riding a bicycle - get out that wallet. They will sue you and you will lose. 

Riding a bike? Be careful out there!

Driving home and annoyed by that spandex wearing, helmeted "target" on two wheels? Take a deep breath and relax - that could be your mom, dad, brother, sister or little kid down the street whose life your driving might end. Breathe deep and remember - saving that life may cost you a few minutes, but failing to drive carefully might cost the life, your life and the lives of those you love.

Injured? Give me a call and we can discuss your case. 

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 I had an interesting call this past week inquiring about potential civil liability for a wrongful death at a ski area. This call reminded me of the tragedy surrounding Natasha Richardson's death last March when she suffered head injuries at a ski area. A few years ago, Mel Orchard (an attorney at Gerry Spence's shop) and I tried a similar case in Wyoming. Our client had fallen (an entirely forseeable event for anyone skiing) into an unpadded, unmarked and partially buried electrical box. The ski industry fights these to the death because they say the responsibility for safety rests with the skier, not the area. In our case, we settled with the utility company that had placed the box and then went to trial against the ski area. While the jury was out we settled with the ski area, and our client's surviving spouse and son were awarded some money to offset their loss of husband and father. The Richardson case raises another important question - whether the emergency medical technicians actually attended to her injuries. An interesting analysis of this question is found on Anderson Cooper's site.  The bottom line from my experience a few years ago is this - ski injury and death cases are very difficult to pursue. State's have enacted Recreational Safety Acts which exempt property owners from liability for simple negligence in many such circumstances. 

Need help with a tough civil case? Give us a call and we may be able to help you find the right lawyer for your case.

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 I am working on my response to a motion to dismiss a civil case under Rule 12(c), which permits a judgment on the pleadings to be granted when, taking all the allegations as true, the moving party is entitled to judgment as a matter of law.  This is a civil case, and the practice in civil cases is different than in criminal cases.  In criminal cases I am often asked why the judge doesn't just dismiss the case. Many defendants are simply certain that the judge will read something and understand immediately that they have been unfairly charged. After that revelation it is only a short jump to certain dismissal. OK - here's the bad news - it doesn't work that way.

If you have been charged in a criminal case a court has already found that there is probable cause to believe you committed a crime.  In a felony case, a grand jury has found probable cause or a magistrate judge did at the preliminary hearing.  So it is pretty unlikely that the case will simply be thrown out before trial, but it actually could happen.  Rule 48 of the Idaho Criminal Rules permits a judge to dismiss a case in the interests of justice (which really does mean any reason) either on motion by the defendant or on his own motion. If the case is dismissed by the judge it may be re-filed if it is a felony, but not so if a misdemeanor.  If it gets dismissed as a misdemeanor, it is gone for good.

But does this happen? Not often. Judges presume that the prosecutor knows more about the case than he or she does, and that is usually the case.  So the Court is more likely to let the prosecutor try to prove the case. The best hope for a "dismissal" is the motion for Judgment of Acquittal based on Criminal Rule 28.  A judge can decide to dismiss after hearing the evidence and concluding that no reasonable trier of fact could conclude there is proof of guilt.  Last summer I had this happen twice - two different judges - acquitted my clients in criminal cases, one a felony and the other a misdemeanor.  If you go to trial you want to make certain that your criminal defense lawyer moves the court to order your acquittal at the conclusion of the State's case.  Just look at your lawyer and say "Rule 28?"  If he or she doesn't do it ask them why!

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