Justia Idaho Supreme Court Opinion Summaries

In this case, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP), along with Michael Reid, an individual, were neighboring landowners in Teton County, Idaho. Axelrod purchased a parcel of land in 2003 that was not accessible by road. Reid, who owned and operated an organic dairy farm nearby, leased land adjacent to Axelrod's parcel. Axelrod had two options for building an access road: build along two easements provided in his deed or build onto an existing dirt road that came through the RLP property. Reid preferred Axelrod to build onto the existing dirt road, which Axelrod did in 2004. However, in 2011, the relationship between Axelrod and Reid began to sour, leading to a series of disputes and legal actions.The District Court of the Seventh Judicial District, State of Idaho, Teton County, initially concluded that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The parties then executed a settlement agreement and stipulated to dismiss the suit. However, disagreements over the implementation of the settlement agreement led to further litigation. The district court granted Axelrod's motion for summary judgment, concluding that Reid, as the nonmoving party, had failed to properly support any assertion of fact or address the assertions of fact in Axelrod’s motion for summary judgment.On appeal, the Supreme Court of the State of Idaho affirmed the district court's grant of summary judgment against Reid individually and affirmed the district court’s judgment dismissing RLP’s counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The Supreme Court also affirmed the judgment of the district court on Axelrod’s breach of contract claim and the judgment of the district court refusing to allow amendment of the pleadings to add Reid Family Limited Partnership (RFLP) as a party. However, the Supreme Court vacated the judgment of the district court dismissing RLP’s trespass claim and remanded for further proceedings. The Supreme Court also vacated the attorney fee award as against RLP and remanded for determination of an appropriate fee award at the conclusion of the proceedings. View "Axelrod v. Reid Limited Partnership" on Justia Law

In this case, the plaintiffs, BABE VOTE and the League of Women Voters of Idaho, challenged two amendments to Idaho's election laws, House Bills 124 and 340, which modified the forms of identification voters can use to prove their identity when registering to vote and voting at the polls. The plaintiffs argued that the bills violated the Idaho Constitution's guarantee of equal protection and unduly burdened the right of suffrage. The Idaho Secretary of State, Phil McGrane, counterclaimed, seeking a judgment declaring that the bills did not violate these rights under either the Idaho or the United States Constitutions. The district court granted the Secretary’s motions and entered judgment in favor of the Secretary.The Supreme Court of the State of Idaho affirmed the decisions of the district court. The court held that the bills were a valid exercise of the legislature’s power to enact conditions on the right of suffrage under Article VI, section 4 of the Idaho Constitution. The court applied the rational basis test and found that the new laws were rationally related to their stated purpose to clarify and create uniformity by requiring only generally accepted, authentic, and reliable forms of identification as a reasonable condition to exercise the right of suffrage. The court also found that the bills did not violate the Equal Protection Clause of the Idaho Constitution. View "BABE VOTE v. McGrane" on Justia Law

The case involves the Idaho Department of Health and Welfare's (the Department) action to set aside a transfer of real property from two Medicaid recipients, Robert Gilbert and Juanita Gilbert, to their five grandchildren. The Department had provided Robert and Juanita with Medicaid benefits totaling over $140,000. In 2005, Robert and Juanita executed two quitclaim deeds transferring their interest in real property to themselves and their grandchildren. After their deaths, the Department filed an action to set aside the two quitclaim deeds, alleging that the estates did not receive adequate consideration for the transfer of their interests in the real property. One of the grandchildren, Earle L. Beason, argued that the Department’s action was barred by the statute of limitations and that Robert and Juanita received adequate consideration for their interests in the property.The District Court of the Seventh Judicial District of the State of Idaho granted the Department’s motion for summary judgment and entered a judgment in favor of the Department setting aside the quitclaim deeds. The court concluded that the Department’s action was timely and that the Department had demonstrated the absence of a genuine issue of material fact regarding adequate consideration. Earle L. Beason appealed the decision.The Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that the Department’s action was timely filed pursuant to Idaho Code section 5-224, the catch-all statute of limitation, which provides a four-year limitation period when an action for relief is not otherwise provided for. The court also affirmed the district court’s grant of summary judgment in favor of the Department because Earle L. Beason did not establish a genuine issue of material fact regarding adequate consideration. View "Idaho Department of Health and Welfare v. Beason" on Justia Law

The case revolves around a premises liability claim filed by Diane Lands against Sunset Manor, LP, and Bingham County Senior Citizens Center, Inc. Lands tripped on an uneven sidewalk outside her apartment building, Sunset Manor, and suffered injuries including a concussion, headaches, chin pain, dizziness, and short-term memory loss. She claimed that her injuries were a result of the fall and sought damages for past and future medical expenses, non-economic damages, and other losses.The District Court of the Seventh Judicial District of the State of Idaho had previously reviewed the case. The court issued a scheduling order setting deadlines for disclosing expert witnesses and completing discovery. Lands failed to meet these deadlines, leading to the exclusion of her expert witnesses at trial. The district court also limited the time period for which non-economic damages could be recovered due to the lack of expert testimony.In the Supreme Court of the State of Idaho, Lands argued that her disclosure deadlines were automatically extended when the trial and pretrial conference were postponed. She also contended that the district court erroneously required non-retained experts to be disclosed at the same time and in the same manner as retained experts. The Supreme Court affirmed the decisions of the district court, ruling that Lands' disclosure deadlines were not extended and that any error in the district court's interpretation of the disclosure requirement for non-retained witnesses was harmless. The court also held that the district court did not err in limiting Lands' non-economic damages. View "Lands v. Sunset Manor, LP" on Justia Law

The Supreme Court of the State of Idaho vacated a lower court's decision to modify Kenneth Richard Rose, Jr.'s sentence. Rose had pleaded guilty to one count of felony aggravated driving under the influence, and the district court sentenced him to six years in prison with one year fixed. The district court indicated it would reconsider Rose's sentence after his direct appeal and stayed the execution of his sentence. Following the conclusion of Rose's appeal, he moved the district court for a reduction of sentence per Idaho Criminal Rule 35(b). The district court agreed and modified Rose's sentence, leading the State to appeal.The Supreme Court found that the district court did not have jurisdiction to modify Rose's sentence because his Rule 35(b) motion was untimely. The court concluded that the 120-day timeframe for filing a Rule 35(b) motion began when the district court initially entered its judgment, not after Rose's appeal concluded. The court held that the district court's decision to stay the execution of Rose's sentence did not extend the timeframe for filing a Rule 35(b) motion. Thus, because Rose's motion was filed more than three years after his sentence was imposed, exceeding the 120 days permitted by Rule 35(b), the district court did not have jurisdiction to modify his sentence. View "State v. Rose" on Justia Law

The Supreme Court of the State of Idaho upheld a decision by the Idaho Industrial Commission that required an employer and its insurance company to pay the full amount of a medical invoice for an employee's workers' compensation claim, even though the employee's medical expenses were fully covered by Medicaid. The employee, Nickole Thompson, worked at Burley Inn, whose workers' compensation insurer was Milford Casualty Insurance Company. After Thompson suffered a work-related injury, Burley Inn and Milford denied her workers' compensation claim for a hip replacement surgery. Thompson underwent the surgery anyway, with Medicaid covering the cost.Thompson later filed a claim with the Industrial Commission, which found the hip replacement surgery was connected to her work injury and awarded her medical benefits based on the full invoice amount for the surgery. Burley Inn and Milford appealed the decision, arguing that the "full invoice" rule should not apply when Medicaid has already covered the medical expenses.The state Supreme Court, however, upheld the Commission's decision, asserting that excluding Medicaid recipients from the full invoice rule could encourage employers to deny workers' compensation claims of workers they suspect of being Medicaid recipients. The court also noted that the full invoice rule was consistent with Idaho's workers' compensation law and was intended to prevent employers from denying legitimate claims. The Court also concluded that the employer and insurer had standing to bring the appeal and that Thompson was not entitled to attorney fees on appeal. View "Thompson v. Burley Inn, Inc." on Justia Law

The case involves the defendant, Kevin James Van Zanten, who was convicted for felony possession of methamphetamine and misdemeanor driving under the influence. Van Zanten challenged the conviction, arguing that the evidence was obtained unlawfully following a stop of the commercial vehicle he was driving. He claimed the stop was based on regulations adopted by the Idaho State Police, which he argued resulted from an unconstitutional delegation of legislative power.In September 2020, an Idaho State Police Trooper observed a 2005 Kenworth truck driven by Van Zanten. The Trooper noted several violations, including an improperly displayed Department of Transportation number, unsecured hazardous material, and other items on the truck. The truck was stopped, and the driver was identified as Van Zanten, whose driving privileges were found to be suspended. A subsequent search of the truck resulted in the finding of drugs, leading to Van Zanten's arrest.At the trial court, Van Zanten moved to suppress the evidence, arguing that the Trooper had no legal basis to stop him. He asserted that the Trooper initiated the stop to investigate state regulations that were unenforceable because the statutes authorizing those regulations unconstitutionally delegated legislative power. The district court denied his motion, leading to his appeal to the Idaho Supreme Court.The Supreme Court of the State of Idaho affirmed the district court's judgment. It held that the Trooper had reasonable suspicion to stop Van Zanten due to specific, articulable facts, thus justifying the stop. The court noted that the inherent danger associated with unsecured hazardous waste and other violations fell within the community caretaking function of law enforcement, and given the nature of the vehicle Van Zanten was driving, the public interest in safety outweighed the limited intrusion of stopping the vehicle. Consequently, the court did not need to address the constitutionality of the statutes in question. The court affirmed Van Zanten’s judgment of conviction. View "State v. Van Zanten" on Justia Law

This case involves a medical debt collection claim between Medical Recovery Services, LLC (MRS), a debt collection service representing Franklin County Medical Center (FCMC), and Cierra Moser, a former FCMC employee. MRS sought to collect debt for medical services provided to Moser at FCMC during her employment. FCMC offered a 50% discount to employees for unpaid medical bills after insurance payments. When Moser's employment ended, FCMC allegedly retracted the discount and assigned the debt to MRS.The magistrate court granted partial summary judgment favoring MRS regarding a minimum principal amount of debt owed by Moser and decided in favor of MRS on the issue of FCMC's right to retract the employee discount. However, the district court reversed the partial grant of summary judgment and remanded all issues for retrial due to disputed facts requiring retrial.On appeal, MRS argued that the district court erred in reversing the partial grant of summary judgment and in remanding all issues for retrial. The Supreme Court of Idaho affirmed the district court's decision, finding that there was a material dispute of fact over the amount of medical debt owed by Moser, which precluded a grant of partial summary judgment. Furthermore, MRS failed to ensure relevant transcripts were included in the record on appeal to the Supreme Court, which was fatal to its position that the district court erred in remanding for a retrial on all issues. View "Medical Recovery Services v. Moser" on Justia Law

In this case, the Supreme Court of the State of Idaho was tasked with answering a certified question of law from the U.S. District Court for the District of Idaho. The question centered on the appropriate point of accrual for wage discrimination claims under the Idaho Human Rights Act (IHRA) and the Idaho Equal Pay Act (IEPA). Plaintiff Lori S. Blasch accused her former employer, HP Inc., of wage discrimination and retaliation under the IHRA and the IEPA.The Idaho Supreme Court held that the one-year limitation period for IHRA claims begins when the pay-setting decision is made and communicated to the employee. As for IEPA claims, the court determined that they are subject to the four-year statute of limitations outlined in Idaho Code section 5-224. Furthermore, the limitation period for IEPA claims begins to run when the employee receives each discriminatory paycheck. The court made these decisions after reviewing the language of the relevant statutes and considering previous court decisions, legislative intent, and public policy. View "Blasch v. HP, Inc." on Justia Law

The Supreme Court of the State of Idaho affirmed a lower court's decision upholding the denial of a preliminary plat application by Renaissance Project Development, LLC for phases two through five of the Shoshone Heights Subdivision. The Twin Falls County Board of Commissioners denied the application due to safety concerns surrounding the ability of residents to evacuate the subdivision in an emergency through a single, gated point of egress.In 2007, Renaissance purchased Shoshone Heights from Casper Southgate, LLC, and obtained approval for a planned unit development (PUD) from the City of Twin Falls. However, the county took over management of the area after the first phase of the subdivision was built. In 2021, Renaissance filed an application seeking approval to construct a thirty-six residential lot subdivision on the property. The county denied the application due to concerns about the lack of a second egress point and the associated safety risks.Renaissance appealed the denial, arguing that the county's decision was arbitrary, capricious, and influenced by bias. It also contended that the denial was fundamentally unfair due to the fact that other subdivisions in the area only had one egress point. However, the court found that the county's decision was rooted in the express approval standard of the health and safety provisions of the Twin Falls City Code, and provided a reasoned statement for the decision, satisfying the requirements of the Idaho Code. Therefore, the court affirmed the lower court's decision dismissing the petition for judicial review. View "Renaissance Project Development, LLC v. Twin Falls" on Justia Law