Simmons rule (Idaho) · Go Syfert
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Simmons rule in Idaho

5 Idaho opinions name it 2 courts 1986–2020 0 in the last five years

The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
State v. Langdongreen
idahoctapp · 1990 · cited in 1 Idaho opinions naming this issue, 2020–2020
2 sentences

2020See State v. Langdon, 117 Idaho 115, 117 , 785 P.2d 679, 681 (Ct. App. 1990) (noting that sanctions for failing to diligently prosecute an appeal from the magistrate division are discretionary and may include dismissal of the appeal for failing to timely file an appellate brief). 2 The State alternatively argues that, even if the district court erred in denying Simmons’s motion for extension of time, there is no remedy available to Simmons because she failed to properly challenge the district court’s reason for dismissing her appeal.

2020See State v. Langdon, 117 Idaho 115, 117 , 785 P.2d 679, 681 (Ct. App. 1990) (noting that sanctions for failing to diligently prosecute an appeal from the magistrate division are discretionary and may include dismissal of the appeal for failing to timely file an appellate brief). 2 The State alternatively argues that, even if the district court erred in denying Simmons’s motion for extension of time, there is no remedy available to Simmons because she failed to properly challenge the district court’s reason for dismissing her appeal.

11
Simmons v. Perkinsgreen
idaho · 1941 · cited in 1 Idaho opinions naming this issue, 1992–1992
2 sentences

1992In Simmons v. Perkins, 63 Idaho 136, 144 , 118 P.2d 740, 744 (1941), we held that “where the owner of real property constructs a way over it for his use and convenience, the mere use thereof by others which in no way interferes with his use will be presumed to be by way of license or permission.” Therefore, without the above-quoted finding of the district court, regarding the establishment of the driveway, the Simmons exception operates to give appellants the presumption of permissiveness.

1992In Simmons v. Perkins, 63 Idaho 136, 144 , 118 P.2d 740, 744 (1941), we held that “where the owner of real property constructs a way over it for his use and convenience, the mere use thereof by others which in no way interferes with his use will be presumed to be by way of license or permission.” Therefore, without the above-quoted finding of the district court, regarding the establishment of the driveway, the Simmons exception operates to give appellants the presumption of permissiveness.

11
Sinnett v. Werelusgreen
idaho · 1961 · cited in 1 Idaho opinions naming this issue, 1992–1992
2 sentences

1992On remand, if Conway rebuts the Simmons presumption of permissiveness, the district court must set forth “with precision and particularity, the origin, course and dimension, on the ground, of the area affected by the easement established, with the right to take further testimony in this respect if deemed necessary.” Sinnett v. Werelus, 83 Idaho 514, 524 , 365 P.2d 952, 957 (1961).

1992On remand, if Conway rebuts the Simmons presumption of permissiveness, the district court must set forth “with precision and particularity, the origin, course and dimension, on the ground, of the area affected by the easement established, with the right to take further testimony in this respect if deemed necessary.” Sinnett v. Werelus, 83 Idaho 514, 524 , 365 P.2d 952, 957 (1961).

11
Cusic v. Givensgreen
idaho · 1950 · cited in 1 Idaho opinions naming this issue, 1986–1986
2 sentences

1986See Cusic v. Givens, 70 Idaho 229, 231 , 215 P.2d 297, 298 (1950).

1986See Cusic v. Givens, 70 Idaho 229, 231 , 215 P.2d 297, 298 (1950).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
North Carolina v. Alford green
scotus · 1970
1 sentence

2019Simmons appeals. 1 See North Carolina v. Alford, 400 U.S. 25 (1970). 1 The alleged constitutional violations at sentencing include the failure to be advised of the Fifth Amendment right to be silent during the presentence investigation, the failure to order a neuropsychological evaluation, and the failure to redact the presentence investigation report.

12019–2019
Shafer v. South Carolina green
scotus · 2001
2 sentences

2015Shafer, 532 U.S. at 51 , 121 S.Ct. at 1272-73 , 149 L.Ed.2d at 191-92 .

2015Shafer, 532 U.S. at 51 , 121 S.Ct. at 1272-73 , 149 L.Ed.2d at 191-92 .

12015–2015
Cardenas v. Kurpjuweit green
idaho · 1989
2 sentences

1992We take note of the case Cardenas v. Kurpjuweit, 116 Idaho 739 , 779 P.2d 414 (1989), wherein the district court concluded that the clear and convincing standard had been met by the party claiming a prescriptive easement to a gravel driveway.

1992We take note of the case Cardenas v. Kurpjuweit, 116 Idaho 739 , 779 P.2d 414 (1989), wherein the district court concluded that the clear and convincing standard had been met by the party claiming a prescriptive easement to a gravel driveway.

11992–1992
West v. Smith green
idaho · 1973
2 sentences

1986The Melendezes argue that the Simmons rule or exception is no longer favored in Idaho. *405 They point particularly to our Supreme Court’s opinion in West v. Smith, supra, where Simmons was mentioned at 95 Idaho at 557 n. 28, 511 P.2d 518 n. 28 .

1986The Melendezes argue that the Simmons rule or exception is no longer favored in Idaho. *405 They point particularly to our Supreme Court’s opinion in West v. Smith, supra, where Simmons was mentioned at 95 Idaho at 557 n. 28, 511 P.2d 518 n. 28 .

11986–1986

Where else courts name it

PA 65 (1997–2026) TX 27 (1971–2020) FL 15 (1971–2023) GA 14 (1975–2026) AZ 13 (2012–2022) CA 12 (1975–2023) MS 11 (1992–2017) NC 8 (1972–1978) SC 6 (1993–2020) WA 6 (1993–2026) WI 5 (1978–2025) AL 5 (1998–2012) ID 5 (1986–2020) HI 4 (1998–2013) MO 4 (1974–2016) CT 3 (1974–1997) TN 3 (1978–2019) LA 3 (1987–2025) VA 3 (1999–2025) IA 3 (2006–2018) MA 3 (1978–2011) OH 3 (2008–2014) NY 3 (1980–2007) WY 3 (1992–2020) AR 3 (1989–2021) NJ 3 (1973–1996) DC 2 (1989–2021) UT 2 (1990–2014) IN 2 (1983–2013) MI 2 (1970–1977) ND 2 (1980–1988) KS 2 (2012–2017) MT 2 (1979–2000) KY 2 (2007–2013) MD 2 (2000–2003) IL 2 (2023–2023) RI 2 (1979–1984) CO 2 (1980–2002)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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