Justia Idaho Supreme Court Opinion Summaries

The case involves the Schrivers, who sought damages after their cat, Gypsy, died following a veterinary procedure and was subjected to an unauthorized necropsy by Dr. Raptosh and Lakeshore Animal Hospital. The Schrivers claimed non-economic damages for emotional distress and loss of companionship, arguing that the emotional bond between pet and owner should be compensable. They also sought economic damages based on the pet's value to them.The District Court of the Third Judicial District of Idaho granted summary judgment in favor of Dr. Raptosh and Lakeshore on several claims, including negligent infliction of emotional distress, intentional infliction of emotional distress, and lack of informed consent. The court denied the Schrivers' claim for emotional distress damages related to trespass to chattels/conversion but allowed the "value to owner" measure of economic damages for the loss of Gypsy.The Supreme Court of Idaho affirmed the district court's decision in part and reversed in part. The court upheld the denial of emotional distress damages for trespass to chattels/conversion, agreeing that such damages are limited to independent torts of negligent or intentional infliction of emotional distress. The court also affirmed the summary judgment on the negligent infliction of emotional distress claim, holding that veterinarians do not have a duty to prevent emotional harm to pet owners. However, the court reversed the summary judgment on the intentional infliction of emotional distress claim related to the unauthorized necropsy, finding that a jury should decide if the conduct was extreme and outrageous. The court affirmed the use of the "value to owner" measure of damages, excluding sentimental value.The case was remanded for further proceedings on the intentional infliction of emotional distress claim. The Schrivers were awarded costs on appeal, but attorney fees were not granted to Dr. Raptosh and Lakeshore, as the primary issue of liability remains unresolved. View "Schriver v. Raptosh" on Justia Law

Catherine Sullivan, trustee of the Catherine Sullivan Family Trust of 2000, owns residential property adjacent to Megan Gruver's equestrian facility, Silver Bell Ranch, in Blaine County, Idaho. Gruver was issued a conditional use permit (CUP) in 2019 to operate the facility, which Sullivan did not appeal. In 2021, Gruver sought modifications to the CUP to hold three events per year, board additional horses, and hire more staff. Sullivan objected, citing concerns about noise, traffic, and property devaluation, but the Blaine County Board of Commissioners approved the modified CUP with conditions.Sullivan appealed the Board's decision to the district court, arguing that the Board erred in categorizing Silver Bell Ranch as an "Outdoor Recreational Facility" rather than an "Agricultural Business" and that the modifications would prejudice her substantial rights. The district court affirmed the Board's decision, finding that Sullivan failed to show how the modifications prejudiced her substantial rights and that her arguments regarding the categorization of the facility were time-barred because she did not appeal the 2019 CUP.The Idaho Supreme Court reviewed the case and affirmed the district court's decision. The Court held that Sullivan's arguments regarding the categorization of Silver Bell Ranch were time-barred and that she failed to establish prejudice to her substantial rights under Idaho Code section 67-5279(4). The Court also found that the district court acted within its discretion in excluding Sullivan's arguments related to prejudice that were raised for the first time in her reply brief. Blaine County was awarded attorney fees on appeal under Idaho Code section 12-117(1), while Gruver was not entitled to attorney fees as she was not an adverse party to Blaine County. Both Blaine County and Gruver were awarded costs on appeal. View "Sullivan v. Blaine County" on Justia Law

Jacob Wilde and Mickayla Taggart, formerly married, are parents to a minor child, E.W. Following their divorce in 2018, Wilde was ordered to pay $143.07 per month in child support. Wilde later filed petitions to modify the custody arrangement and child support, citing Taggart's alleged incapacity and unemployment. Taggart responded, explaining her inability to work due to an autoimmune disease and requested child support modification based on the Idaho Child Support Guidelines.The magistrate court found that Taggart's income had been minimal since the petition was filed and imputed her income at minimum wage. Wilde's income was determined to be $58,240 annually. The court retroactively modified child support to $420.34 per month starting August 2019, creating an arrearage for Wilde. Wilde's motion to reconsider was denied, and the magistrate court reaffirmed its decision, adjusting the child support amount to $485.34 from June 2021.Wilde appealed to the district court, which affirmed the magistrate court's decision. The district court found that the magistrate court had substantial evidence to support its findings and did not abuse its discretion in making the child support modification retroactive.The Idaho Supreme Court reviewed the case and upheld the district court's decision. The court found that the magistrate court acted within its discretion, supported by substantial evidence of the parties' changed incomes. The court noted that Wilde had been aware of the potential for retroactive modification and had not disputed the child support calculations. The Supreme Court awarded attorney fees and costs to Taggart, deeming Wilde's appeal frivolous and without foundation. View "Wilde v. Taggart" on Justia Law

In this case, the State of Idaho removed five minor children from their parents' home following allegations of physical abuse. The children ranged in age from sixteen years to fourteen months. Law enforcement responded to a report of an altercation between the mother and the eldest child, during which the mother admitted to hitting the child with a plastic hanger. Other children reported frequent physical discipline, including being hit with belts and hands. The children were declared to be in imminent danger and were removed from the home.The Bannock County Prosecutor’s Office filed a petition under the Child Protective Act (CPA) to place the children in the custody of the Idaho Department of Health and Welfare (IDHW). The magistrate court held a shelter care hearing and found reasonable cause to believe the children were in danger, placing them in temporary custody of IDHW. The parents objected, arguing that the removal violated their constitutional rights and that the magistrate court’s findings were unsupported by substantial evidence.The Idaho Supreme Court reviewed the case and affirmed the magistrate court’s adjudicatory decree. The Court declined to rule on the constitutionality of the initial removal because the parents failed to raise the issue in the lower court. The Court also found that the challenge to the shelter care order was moot because it was supplanted by the adjudicatory decree. The Court held that the magistrate court did not abuse its discretion by allowing the older children to remain in the courtroom during the hearing and found that substantial and competent evidence supported the magistrate court’s decision to vest legal custody of the children in IDHW. The Court also declined to consider the parents' argument under the Idaho Parental Rights Act because it was raised for the first time on appeal. View "IDHW v. Doe" on Justia Law

John David Wurdemann was charged and convicted of seven felonies related to a 2000 attack on a woman in Canyon County, Idaho. Sixteen years later, a district court granted his petition for post-conviction relief, vacating his convictions due to ineffective assistance of counsel. This decision was affirmed by the Idaho Supreme Court in 2017. Wurdemann has not been retried since.Wurdemann filed a petition under the Idaho Wrongful Conviction Act, seeking compensation and a certificate of innocence. The State opposed the petition and moved for summary judgment, which the district court granted. The district court concluded that Wurdemann had not established that the basis for vacating his conviction was not legal error unrelated to his factual innocence, as required by the Act.The Idaho Supreme Court reviewed the case and interpreted the statutory language of the Idaho Wrongful Conviction Act. The Court held that the phrase “not legal error unrelated to his factual innocence” means “legal error related to his factual innocence.” The Court concluded that the ineffective assistance of counsel claim, which led to the reversal of Wurdemann’s convictions, did not establish his factual innocence. The reversal was based on the improper admission of lineup evidence, not on evidence showing Wurdemann was actually innocent. Therefore, Wurdemann could not satisfy the statutory requirement, and the district court's grant of summary judgment to the State was affirmed. View "Wurdemann v. State" on Justia Law

In this case, the appellant, Chitta Roy, challenged the Idaho Department of Health and Welfare's (the "Department") denial of her criminal history background clearance during her certified family home (CFH) recertification. Roy had a 2008 conviction for involuntary manslaughter, which was dismissed in 2011 under Idaho Code section 19-2604 after she successfully completed probation. Despite this, the Department denied her 2021 application for background clearance, citing the conviction as a disqualifying crime under its updated rules.The District Court of the Seventh Judicial District of Idaho upheld the Department's decision, rejecting Roy's arguments that the dismissal of her conviction should preclude the Department from denying her clearance and that the Department should be bound by its 2009 decision to grant her an exemption. The district court also determined that Roy failed to show substantial prejudice from the denial, as the Department could still approve her CFH recertification through a separate process.The Supreme Court of Idaho reviewed the case and found that the district court erred in its conclusions. The Supreme Court held that the Department improperly based its denial on the dismissed conviction, which, under Idaho Code section 19-2604, should be treated as if it never existed. The Court also determined that the case was ripe for adjudication and that Roy's substantial rights were prejudiced by the Department's denial. The Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. Roy was awarded costs on appeal. View "Roy v. Idaho Department of Health and Welfare" on Justia Law

John David Wurdemann was convicted of seven felonies related to a 2000 attack on a woman in Canyon County, Idaho. Sixteen years later, a district court granted his petition for post-conviction relief, vacating his convictions due to ineffective assistance of counsel. This decision was affirmed by the Idaho Supreme Court in 2017. Wurdemann was not retried. In 2021, Idaho enacted the Idaho Wrongful Conviction Act, which allows for compensation for wrongfully convicted individuals who meet specific criteria. Wurdemann filed a petition under this Act seeking compensation and a certificate of innocence.The district court granted the State's motion for summary judgment, concluding that Wurdemann had not established that the basis for vacating his conviction was not legal error unrelated to his factual innocence, as required by the Act. Wurdemann appealed this decision.The Idaho Supreme Court reviewed the case and interpreted the statutory language of the Idaho Wrongful Conviction Act. The Court held that the phrase “not legal error unrelated to his factual innocence” means “legal error related to his factual innocence.” The Court concluded that the legal error in Wurdemann’s case—ineffective assistance of counsel due to failure to challenge a suggestive police lineup—did not establish his factual innocence. The reversal of his convictions was based on the deficient performance of his trial attorneys, not on evidence proving his innocence. Therefore, Wurdemann did not meet the statutory requirement for compensation under the Act.The Idaho Supreme Court affirmed the district court’s grant of summary judgment in favor of the State, concluding that Wurdemann could not satisfy the necessary element of showing that the basis for reversing his conviction was related to his factual innocence. View "Wurdemann v. State" on Justia Law

The case involves property owners Brenda and Ray von Wandruszka and Robert R. Davis, who sued the City of Moscow after the city adopted a resolution in 2021 revising its utility billing process. The new policy required property owners to sign contracts making them responsible for tenants' unpaid water bills, under threat of water service termination. The plaintiffs signed the contracts under protest and claimed they were unenforceable adhesion contracts signed under duress.The District Court of the Second Judicial District of Idaho reviewed cross-motions for summary judgment. The court ruled that the city was not authorized to recover tenants' unpaid utility charges from property owners, citing City of Grangeville v. Haskin. However, it also ruled that the city could require owner-occupied properties to enter agreements to pay for water consumed. Both parties appealed the split decision.The Supreme Court of Idaho reviewed the case and clarified that City of Grangeville does not prohibit municipalities from collecting tenants' unpaid utilities from property owners if there is a contractual basis. The court found that the utility billing agreements were not secured under duress, as the city's actions were not coercive. However, the court determined that the lien provisions in the agreements were too vague and indefinite to be enforceable, rendering the contracts invalid.The Supreme Court of Idaho affirmed the district court's summary judgment in favor of the plaintiffs regarding tenant-occupied properties but reversed the summary judgment in favor of the city concerning owner-occupied properties. The case was remanded for further proceedings consistent with the opinion. The plaintiffs were awarded costs as the prevailing party, but no attorney fees were granted to either side. View "Von Wandruszka v. City of Moscow" on Justia Law

Roberta Evans underwent a total hip replacement surgery performed by Dr. Mark B. Wright at St. Luke’s Magic Valley Regional Medical Center. Post-surgery, Evans experienced persistent pain and discomfort, which led her to seek a second opinion. Another doctor confirmed that her hip bone socket was abnormally anteverted, and subsequent revision surgery revealed a periprosthetic joint infection. Evans filed a lawsuit against Dr. Wright and St. Luke’s, alleging negligence in their follow-up care and treatment.The District Court of the Fifth Judicial District of Idaho dismissed Evans’s case, ruling that her claim was barred by the two-year statute of limitations under Idaho Code section 5-219(4). The court found that Evans’s surgical complications were objectively ascertainable by March 4, 2019, indicating that some damage was present. Her motion for reconsideration was denied.The Supreme Court of Idaho affirmed the district court’s decision. The court held that Evans’s medical malpractice claim was time-barred, as the statute of limitations began when her symptoms indicated some damage, which was before April 6, 2019. The court also found that the district court did not err in dismissing Evans’s complaint and that her equitable estoppel argument was without merit. The court denied attorney fees to both parties but awarded costs to Dr. Wright and St. Luke’s as the prevailing parties. View "Evans v. Wright" on Justia Law

Grand Peaks, a nonprofit healthcare provider, applied for a full property tax exemption for its clinics and administrative offices in Rexburg, Idaho, under Idaho Code section 63-602C. Grand Peaks argued that it qualifies as a charitable organization and uses its property exclusively for charitable purposes, providing healthcare to underserved communities regardless of patients' ability to pay. The Madison County Board of Equalization granted a partial tax exemption of sixty-five percent, citing concerns about competition with for-profit healthcare providers and the revenue generated from insured patients.Grand Peaks appealed to the District Court of the Seventh Judicial District, which found that Grand Peaks qualified as a charitable organization and used its property exclusively for charitable purposes. However, the district court remanded the case to the Board for further fact-finding, suggesting that the partial tax exemption might be appropriate due to the "revenue-generating" nature of some of Grand Peaks' activities. The district court vacated the Board's sixty-five percent exemption, deeming it arbitrary and capricious.The Supreme Court of Idaho reviewed the case and reversed the district court's order for remand. The Court held that Grand Peaks is entitled to a full tax exemption under Idaho Code section 63-602C. The Court clarified that the proper test for tax exemption focuses on the exclusive use of the property for charitable purposes, not the income generated from the property. The Court found substantial and competent evidence supporting that Grand Peaks' properties are used exclusively for its charitable mission. The case was remanded to the district court with instructions to grant Grand Peaks a one hundred percent tax exemption for the properties at issue. Grand Peaks was awarded costs on appeal. View "Upper Valley Community Health Svcs, Inc. v. Madison County" on Justia Law