factual basis claim in Idaho

2014This Court found Abbott’s assertion that mental disease or psychotropic medication rendered him incompetent and prevented him from pursuing challenges to his conviction during the one-year period was sufficient to raise factual issues and intertwining legal issues as to whether he was 1 This Court was referencing Charboneau v. State, 144 Idaho 900, 904-05 , 174 P.3d 870, 874-75 (2008), in which the Idaho Supreme Court recognized that the limitation period may be postponed until the petitioner has discovered the factual basis for the claim where the post- conviction claim raises important due p

2014This Court found Abbott’s assertion that mental disease or psychotropic medication rendered him incompetent and prevented him from pursuing challenges to his conviction during the one-year period was sufficient to raise factual issues and intertwining legal issues as to whether he was 1 This Court was referencing Charboneau v. State, 144 Idaho 900, 904-05 , 174 P.3d 870, 874-75 (2008), in which the Idaho Supreme Court recognized that the limitation period may be postponed until the petitioner has discovered the factual basis for the claim where the post- conviction claim raises important due p

2024And it certainly does not imply that the factual-basis requirement of Fed.R.Crim.P. 12 11(f) and its state-law counterparts comes from the Constitution.”); Medina v. People, 535 P.3d 82, 90 (Colo. 2023) (“[Whether] a guilty plea is voluntary, knowing, and intelligent necessarily depends on the circumstances of each case.

2024And it certainly does not imply that the factual-basis requirement of Fed.R.Crim.P. 12 11(f) and its state-law counterparts comes from the Constitution.”); Medina v. People, 535 P.3d 82, 90 (Colo. 2023) (“[Whether] a guilty plea is voluntary, knowing, and intelligent necessarily depends on the circumstances of each case.

2010In addition, two decisions of our Supreme Court, Rhoades v. State, 148 Idaho 247, 250-51 , 220 P.3d 1066, 1069-70 (2009), and Charboneau v. State, 144 Idaho 900, 904-05 , 174 P.3d 870, 874-75 (2007), indicate that where the post-conviction claim raises an important due process issue, there may be a tolling of the statute of limitation until the petitioner knows or reasonably should know of the factual basis of the claim.

2010In addition, two decisions of our Supreme Court, Rhoades v. State, 148 Idaho 247, 250-51 , 220 P.3d 1066, 1069-70 (2009), and Charboneau v. State, 144 Idaho 900, 904-05 , 174 P.3d 870, 874-75 (2007), indicate that where the post-conviction claim raises an important due process issue, there may be a tolling of the statute of limitation until the petitioner knows or reasonably should know of the factual basis of the claim.

2026See 740 F.3d 1302 , 1320–22 (9th Cir. 2014) (en banc), abrogated by, Shinn v. Ramirez, 596 U.S. 366 (2022), as recognized in Hampton v. Shinn, 143 F.4th 1047 (9th Cir. 2025).

2025While that motion was pending, the Ninth Circuit issued Dickens v. Ryan, 740 F.3d 1302 (9th Cir. 2014) (en banc), abrogated by Shinn v. Ramirez, 596 U.S. 366 (2022), as recognized in Hampton v. Shinn, 143 F.4th 1047 (2025), which held that an inadequately supported claim, decided on the merits by a state court, could become a new procedurally defaulted claim in federal court if the petitioner provided new evidence that changed the factual basis of the claim such that it resulted 1 In federal court, a procedural default occurs in two instances.

2026See 740 F.3d 1302 , 1320–22 (9th Cir. 2014) (en banc), abrogated by, Shinn v. Ramirez, 596 U.S. 366 (2022), as recognized in Hampton v. Shinn, 143 F.4th 1047 (9th Cir. 2025).

2025While that motion was pending, the Ninth Circuit issued Dickens v. Ryan, 740 F.3d 1302 (9th Cir. 2014) (en banc), abrogated by Shinn v. Ramirez, 596 U.S. 366 (2022), as recognized in Hampton v. Shinn, 143 F.4th 1047 (2025), which held that an inadequately supported claim, decided on the merits by a state court, could become a new procedurally defaulted claim in federal court if the petitioner provided new evidence that changed the factual basis of the claim such that it resulted 1 In federal court, a procedural default occurs in two instances.

2013In Amboh v. State, 149 Idaho 650 , 239 P.3d 448 (Ct. App. 2010), this Court said “in cases where equitable tolling was allowed, the petitioner was alleged to have been unable to timely file a petition due to extraordinary circumstances beyond his effective control, or the facts underlying the claim were hidden from the petitioner by unlawful state action.” Id. at 653 , 239 P.3d at 451 (internal citations omitted).

2013In Amboh v. State, 149 Idaho 650 , 239 P.3d 448 (Ct. App. 2010), this Court said “in cases where equitable tolling was allowed, the petitioner was alleged to have been unable to timely file a petition due to extraordinary circumstances beyond his effective control, or the facts underlying the claim were hidden from the petitioner by unlawful state action.” Id. at 653 , 239 P.3d at 451 (internal citations omitted).

2021See Metcalf, 116 Idaho 622 , 778 P.2d 744 (first addressing whether an employee handbook altered the terms under which an employee could be fired, then addressing whether an at-will employee could pursue a good faith and fair dealing claim against their employer). 17 In light of the above, we hold that summary judgment was appropriate on Knudsen’s good faith and fair dealing claim because he did not demonstrate a triable issue of material fact as to whether Simplot deprived him of the benefit of any term of his employment agreement.

2021See Metcalf, 116 Idaho 622 , 778 P.2d 744 (first addressing whether an employee handbook altered the terms under which an employee could be fired, then addressing whether an at-will employee could pursue a good faith and fair dealing claim against their employer). 17 In light of the above, we hold that summary judgment was appropriate on Knudsen’s good faith and fair dealing claim because he did not demonstrate a triable issue of material fact as to whether Simplot deprived him of the benefit of any term of his employment agreement.

2010However, as we noted in Chico-Rodriguez v. State, 4 141 Idaho 579, 582 , 114 P.3d 137, 140 (Ct. App. 2005), American courts generally have applied equitable tolling only in rare and exceptional circumstances beyond the petitioner’s control that prevented him or her from filing a timely petition.

2010However, as we noted in Chico-Rodriguez v. State, 4 141 Idaho 579, 582 , 114 P.3d 137, 140 (Ct. App. 2005), American courts generally have applied equitable tolling only in rare and exceptional circumstances beyond the petitioner’s control that prevented him or her from filing a timely petition.