Justia Idaho Supreme Court Opinion Summaries

Articles Posted in Contracts
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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

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This case involved a property dispute between neighbors Robert and Debra Talburt and Miles and Leanne Millard in Idaho. The Millards sought to establish their rights to a disputed tract of land and two easements, as well as breach of contract damages for maintenance of a shared well. The Talburts countered by constructing a fence within the roadway easement, stating they were relocating the roadway easement, and locking the pump house for the shared well. The Supreme Court of Idaho affirmed the district court's judgement in favor of the Millards on their claims related to the easements and ordered the Talburts to remove the fence and cease efforts to block access to the shared well. The court also found the Talburts' attempt to relocate the roadway easement to be unlawful, invalid, and void. However, the district court found that the Millards had abandoned their breach of contract claim and failed to establish a right to the disputed property. The Supreme Court also affirmed the district court's award of a portion of the Millards' attorney fees and costs to them. View "Millard v. Talburt" on Justia Law

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This case involves a dispute between Melissa Sanchez, a tenant, and Chris and Jennifer Pickering, her landlords, over the terms of a lease agreement for a mobile home owned by the Pickerings. Sanchez believed the agreement was a lease-to-own contract, while the Pickerings asserted it was a lease with a purchase option contract. After the Pickerings initiated an eviction action due to Sanchez's alleged violations of the agreement, Sanchez caused extensive damage to the home.The Pickerings sued Sanchez for waste, claiming she caused $40,000 in damages and sought treble damages. Sanchez counterclaimed, alleging violation of the Idaho Consumer Protection Act (ICPA), breach of contract, unjust enrichment, and retaliatory eviction. The district court found Sanchez liable for damages to the residence and awarded treble damages. It also determined that there was no deception on the Pickerings' part to sustain Sanchez's ICPA claim, the agreement was unenforceable due to a lack of mutual understanding, and that the Pickerings were unjustly enriched by the $10,000 down payment and offset the Pickerings' damages award by this amount. The remaining claims were dismissed.On appeal, the Supreme Court of Idaho affirmed the district court's decision. The court found substantial and competent evidence supporting the district court's decision that the Pickerings did not engage in a deceptive act under the ICPA. The court also rejected Sanchez's contention that the district court's damages award should have been reduced to reflect an insurance payment received by the Pickerings as Sanchez failed to provide an adequate record for review. Finally, the court upheld the district court's unjust enrichment award, finding that Sanchez had not demonstrated an abuse of discretion. The Pickerings were awarded attorney fees for having to respond to the collateral source issue. View "Pickering v. Sanchez" on Justia Law

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Two online fundraising companies, Snap! Mobile, Inc. ("Snap") and Vertical Raise, LLC ("Vertical Raise"), were involved in a dispute. Snap accused Vertical Raise and its CEO, Paul Landers, of poaching its sales representatives and customers, which violated non-compete and confidentiality provisions in the former sales representatives’ employment agreements with Snap. The trial court granted Snap a preliminary injunction to prevent further violations and partially ruled in Snap's favor on some claims. A jury trial on damages resulted in an award of $1,000,000 to Snap. However, the trial court increased the award to $2,310,021. Both parties appealed. The Supreme Court of Idaho affirmed the trial court's award of discretionary costs for expert witness fees but reversed the trial court’s order granting an additur or new trial. The Supreme Court ordered the trial court to enter a judgment consistent with the original jury award. The Supreme Court also reversed the trial court’s decision granting Snap a permanent injunction. In a separate contempt proceeding, the Supreme Court affirmed the contempt court's decision to dismiss contempt charges against Vertical Raise and Paul Croghan, a former Snap employee. The contempt court had determined the preliminary injunction was vague, overbroad, and unenforceable. View "Snap! Mobile v. Vertical Raise" on Justia Law

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In an appeal from a property dispute in Ketchum, Idaho, the Supreme Court of the State of Idaho affirmed the lower court's judgment, in part, and vacated and remanded the case, in part, for further proceedings. The dispute arose when Trustees Glen Miller and Cynthia Anderson attempted to build a home on a lot they purchased in the Rocking Ranch No. 3 subdivision. The Rocking Ranch No. 3 Property Owners’ Association denied their application to construct the home and asserted several counterclaims to recover unpaid homeowners association (HOA) assessments. The district court granted summary judgment to the Association on Miller and Anderson’s claims and dismissed the Association’s counterclaims. On appeal, the Supreme Court of the State of Idaho affirmed the district court's dismissal of the Association’s counterclaims, concluding that the Association failed to establish its breach of contract counterclaim because it had not established two elements of the prima facie case: breach of the contract and damages resulting from the breach. The Supreme Court of the State of Idaho also vacated and remanded the district court's award of attorney fees to the Association for further proceedings, finding that the Association was not entitled to recover attorney fees for the counterclaims on which it did not prevail. View "Miller v. Rocking Ranch No. 3" on Justia Law

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The Supreme Court of the State of Idaho ruled on a dispute between TCR, LLC, a developer, and Teton County. The developer had sought to record a condominium plat for a planned unit development, but the County refused to do so, arguing that the developer had not submitted final site plans, architectural designs, or landscape drawings for review. The developer filed suit, alleging breach of contract and seeking declaratory and injunctive relief to compel the County to record the condominium plat. The district court granted the developer's motion for summary judgment on its declaratory and injunctive relief claim and denied the County's motion for summary judgment on the same claim. The court also denied all motions to reconsider. The Supreme Court of Idaho affirmed the district court's decision in part, reversed in part, and remanded for further proceedings. The court held that the County's refusal to record the condominium plat violated the Idaho Condominium Property Act and that the County did not have a valid reason for its refusal. The court also found that the district court erred in granting summary judgment to the County on the developer's breach of contract claim, concluding that genuine issues of material fact remained. The case was remanded for further proceedings. View "TCR, LLC v. Teton County" on Justia Law

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In this case, the Supreme Court of the State of Idaho upheld a lower court's summary judgment in favor of the defendants, George and Jesse’s Les Schwab Tire Store, Inc., and two of its owners, Bruce and Richard Byram. The plaintiff, Adam Davis, had been employed as an assistant manager at Les Schwab from April 2016 till June 2019. In March 2019, there was a shortage in the cash deposits and surveillance footage showed Davis bending down out of camera view in the area where the cash deposits were kept while he was alone in the store. This led to Davis being arrested and charged with grand theft, and his employment was terminated. Although the charges against Davis were later dropped, he sued the defendants for breach of his employment contract, false arrest, defamation per se, and for knowingly giving a false report to the police. The district court granted the defendants’ motion for summary judgment on all of Davis’s claims. The Supreme Court affirmed the lower court's decision, finding no genuine issue of material fact that could support Davis’s claims. The court found that Davis was an at-will employee who could be terminated without cause and that there was no evidence to show that the defendants had acted with malice. The court also found that the plaintiff's attorney had violated Rule 11.2 by submitting arguments that were not well grounded in fact, and awarded a portion of the defendants' attorney fees to be paid by the plaintiff's counsel. View "Davis v. George and Jesse's Les Schwab Tire Store, Inc." on Justia Law

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The case revolved around a disagreement over a parking agreement related to a property owned by Midtown Ventures, LLC ("Midtown"). In 1999, restaurant owners Thomas and Teresa Capone ("the Capones") agreed with the Idaho Youth Ranch to allow the Capones’ customers to park in the Idaho Youth Ranch’s adjoining lot. In 2008, a group of nonprofit organizations, including the Capones and the Idaho Youth Ranch, signed an agreement to relocate the parking area to accommodate a proposed workforce housing project. However, the 2008 Agreement was not finalized, and the project was eventually abandoned. In 2018, Midtown purchased the Idaho Youth Ranch property and attempted to enforce the 2008 Agreement to relocate the parking area, but was unsuccessful. Midtown then sued the Capones for breach of contract and specific performance. The district court granted summary judgment in favor of the Capones, concluding that Midtown lacked standing to challenge the 2008 Agreement and that the agreement was unenforceable. On appeal, the Supreme Court of the State of Idaho affirmed the lower court's decision, agreeing that the 2008 Agreement was merely an "agreement to agree" and not an enforceable contract. The court also held that Midtown had standing to bring the suit as a property owner, but failed to show that the 2008 Agreement was a valid or enforceable contract. It also found that Midtown waived its challenge to the district court’s evidentiary rulings and its argument that the district court erred in denying the equitable remedy of promissory estoppel. The Court concluded that the Capones are entitled to attorney fees on appeal. View "Midtown Ventures, LLC v. Capone" on Justia Law

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Between 2015 and 2019, BitterSweet Ranch and its managers (“BitterSweet”) leased three parcels of farmland from Frank Sullivan and two of his business entities, The Green Desert, LLC, and The Sullivan Limited Partnership (collectively, “Sullivan”). The parties signed three identical five-year leases (“the Leases”) involving three separate parcels of real property, each owned by one of the three Sullivan parties. The Leases specified that Sullivan was to be responsible for payment of the property taxes, but that those parties were to be reimbursed by BitterSweet, and that BitterSweet was to be responsible for bi-annual rent payments, utilities, and water assessments. For a variety of reasons, the parties purportedly orally agreed to modify the Leases to offset amounts owed to each other throughout the terms of the Leases. Shortly before the Leases were set to expire at the end of their five-year terms, Sullivan claimed that BitterSweet was in breach of the Leases for its alleged failure to make timely rent payments, to pay all property taxes, and to pay the water assessments pursuant to the terms of the Leases. Sullivan then filed three lawsuits (one for each of the Leases and in the names of each of the three parties) in district court. The district court ordered the cases consolidated and then granted summary judgment in favor of BitterSweet, concluding that a genuine issue of material fact had not been created as to whether BitterSweet had breached the Leases. Sullivan appealed the adverse order. Finding no reversible error, the Idaho Supreme Court affirmed. View "Sullivan v. BitterSweet Ranch, LLC" on Justia Law

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After suffering personal injuries and property damage in a multi-car collision with an underinsured motorist, Kelly Lynn Christmann filed suit against her insurer, State Farm Mutual Automobile Insurance Company (“State Farm”). Christmann was seeking to obtain the underinsured motorist benefits provided under her contract of insurance, which she claimed State Farm failed to pay in an amount justly due under her policy. She also alleged that certain terms of her insurance agreement violate public policy. State Farm argued that Christmann waived her rights to additional benefits by failing to comply with the contractual obligations of her insurance policy, thereby prejudicing State Farm’s right to subrogation against the underinsured motorist. The district court awarded summary judgment to State Farm in determining it had been prejudiced by Christmann’s conduct and that the terms of the insurance policy were valid. The court also denied Christmann’s motion for reconsideration and her Rule 60(b) motion for relief. Christmann appealed. Because the record showed State Farm fully settled its claims against the underinsured motorist and waived its subrogation rights, the Idaho Supreme Court concluded it suffered no actual prejudice from Christmann’s actions. Accordingly, the judgment was reversed. View "Christmann v. State Farm Mutual Automobile Insurance Co." on Justia Law