Justia Idaho Supreme Court Opinion Summaries

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law

A mother and her fiancé filed a petition to terminate the biological father's parental rights and allow the fiancé to adopt the child. The mother did not serve the father with the petition, and he did not participate in the proceedings. The magistrate court terminated the father's parental rights and granted the adoption. The father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. The magistrate court denied the second motion, citing res judicata. The district court reversed this decision, finding that the father's due process argument warranted consideration.The Idaho Supreme Court reviewed the case. The court held that the father's Rule 60(b)(4) motion, which alleged a fundamental error violating his constitutional right to due process, was not barred by res judicata. The court applied the fundamental error doctrine, which allows for exceptions to procedural bars when a fundamental constitutional right is at stake. The court also rejected the mother's arguments that the father's motion was barred by the doctrines of claim splitting, invited error, appellate waiver, and the law of the case.The Idaho Supreme Court affirmed the district court's decision to remand the case to the magistrate court for an evidentiary hearing to determine whether the father's Rule 60(b)(4) motion was timely and whether the termination and adoption judgment was void. The court also awarded the father partial attorney fees on appeal for defending against certain arguments made by the mother. View "Doe v. Doe" on Justia Law

Sherry Cole filed a formal complaint against Rocky Mountain Power (RMP) alleging she had been overbilled due to her power meter being cross-connected with her neighbor’s. Initially, an RMP employee confirmed the cross-connection and credited her account with $1,256.45. However, subsequent tests revealed no cross-connection, leading RMP to remove the credit and instead apply a $450 credit for the inconvenience. Cole then filed a complaint with the Idaho Public Utilities Commission, which dismissed her complaint due to lack of evidence of overcharging. Cole's motion for reconsideration was also denied by the Commission.Cole appealed to the Idaho Supreme Court. The Commission had reviewed Cole’s complaint, RMP’s billing calculations, and an analysis by Jon Kruck, an investigator, which concluded that Cole’s energy usage was consistent and did not indicate a cross-connection. The Commission found no substantial evidence supporting Cole’s claims and dismissed her complaint. Cole’s petition for reconsideration was denied as she failed to present new evidence or demonstrate that the dismissal was unreasonable or unlawful.The Idaho Supreme Court affirmed the Commission’s decision, finding that the Commission’s factual findings were supported by substantial and competent evidence. The Court noted that Cole relied on anecdotal evidence and did not provide sufficient proof to counter the Commission’s findings. Additionally, the Court held that Cole’s constitutional arguments were waived as they were raised for the first time on appeal and were not supported by sufficient legal authority. The Court also denied Cole’s request for attorney fees, as pro se litigants are not entitled to such fees.The Idaho Supreme Court affirmed the orders of the Idaho Public Utilities Commission dismissing Cole’s complaint and denying her petition for reconsideration. View "Cole v. IPUC" on Justia Law

Medical Recovery Services, LLC (MRS), a medical debt collector, sought to collect $460 from Katrina Melanese (now Katrina Sullivan) for an emergency room visit in September 2017. Sullivan was treated at Eastern Idaho Regional Medical Center (EIRMC) by Intermountain Emergency Physicians (IEP), which did not collect insurance information directly from patients. Sullivan provided her insurance information to EIRMC, but IEP billed her outdated insurance information from a previous visit. When the outdated insurers denied the claim, IEP assigned the bill to MRS for collection.The magistrate court ruled in favor of Sullivan, finding that an implied condition precedent existed, requiring IEP to bill Sullivan’s insurance before seeking payment from her. The district court affirmed the magistrate court’s decision, agreeing that the condition precedent was not satisfied because IEP did not make reasonable efforts to obtain Sullivan’s correct insurance information.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The court held that an implied-in-fact contract existed between IEP and Sullivan, and that the contract included a condition precedent requiring IEP to bill Sullivan’s insurance before seeking payment from her. The court found substantial and competent evidence supporting the magistrate court’s finding of the condition precedent, noting that Sullivan provided her insurance information to EIRMC and that IEP’s general practice was to bill insurance before seeking payment from patients. The court also rejected MRS’s argument that the federal Emergency Medical Treatment and Labor Act (EMTALA) prevented the application of the condition precedent in emergency room settings.The court concluded that IEP failed to make reasonable efforts to satisfy the condition precedent and, therefore, MRS could not collect the debt from Sullivan. The court awarded attorney fees and costs on appeal to Sullivan. View "Medical Recovery Services, LLC v. Melanese" on Justia Law

Husband and Wife divorced in 2020, with Husband required to pay child support and attorney fees. Two years later, Wife initiated a contempt proceeding against Husband for failing to comply with the divorce decree. On the day of the contempt trial, Husband informed the court he was unable to attend due to vehicle issues. The magistrate court proceeded with the trial in his absence, found him in criminal contempt, and sentenced him to 70 days in jail, with 50 days suspended, and ordered him to pay additional attorney fees.The district court affirmed the magistrate court's decision to hold the trial in Husband's absence but reversed the incarceration sanction, finding insufficient evidence that Husband waived his right to counsel. The district court concluded that the magistrate court violated Idaho Rule of Civil Procedure 75(l)(1) by imposing incarceration without an attorney present to represent Husband.The Idaho Supreme Court reviewed the case and determined that the magistrate court erred in holding the contempt trial in Husband's absence. The court held that a contemnor's right to be present at a criminal contempt trial is protected under the Sixth Amendment, similar to a criminal defendant's right. The court concluded that Husband's willful absence did not constitute a knowing, intelligent, and voluntary waiver of his right to be present. The proper procedure would have been to issue a writ of attachment to ensure Husband's attendance.The Idaho Supreme Court reversed the district court's decision and remanded the case with instructions to vacate the order of contempt and remand to the magistrate court for further proceedings. The court also found the district court's failure to address Wife's request for attorney fees harmless, as Husband's appeal was not frivolous. No attorney fees were awarded on appeal, and costs were awarded to Husband. View "Salazar v. Salazar" on Justia Law

Lance A. Roberts appealed the district court's decision affirming the magistrate court's denial of his Idaho Criminal Rule 35 motion in a misdemeanor DUI case, his Rule 35 motions in felony DUI cases, and the dismissal of his petitions for post-conviction relief in those felony DUI cases. Roberts sought to amend his multiple DUI convictions over the past two decades, arguing that his April 1998 conviction for a second "adult" misdemeanor DUI should have been charged as a second "juvenile" misdemeanor DUI. He claimed this error had a domino effect, leading to subsequent DUIs being charged as felonies and resulting in a persistent violator sentencing enhancement in his most recent felony DUI case.The magistrate court initially granted Roberts' Rule 35 motion to amend his April 1998 conviction, but the State's motion to reconsider was denied. Roberts then filed multiple motions and petitions to amend his subsequent DUI convictions and eliminate the persistent violator enhancement. The magistrate court denied these motions, and the district court affirmed, concluding that neither Rule 35(a) nor post-conviction relief statutes authorized the requested relief. The district court also reversed the magistrate court's amendment of the April 1998 conviction and dismissed Roberts' petitions for post-conviction relief.The Idaho Supreme Court reviewed the case and upheld the district court's decisions. The Court held that Idaho Criminal Rule 35(a) does not allow for the amendment of a criminal conviction and is limited to correcting illegal sentences apparent from the face of the record. The Court also affirmed that Idaho Code section 19-4901(a) does not permit the relief Roberts sought, as his claims were time-barred and could have been raised on direct appeal. Consequently, the Court affirmed the district court's denial of Roberts' motions and petitions for post-conviction relief. View "State v. Roberts" on Justia Law

Jennifer and Jesse Smith divorced in 2017 after fifteen years of marriage. Jennifer, a stay-at-home mother, and Jesse, a construction superintendent, entered into a Marital Settlement Agreement requiring Jesse to pay Jennifer spousal support until January 1, 2025. The agreement included a "Review Term" stating that spousal support would be reviewed every two years. In 2018, Jesse unilaterally reduced the spousal support payments and later stopped paying altogether, leading Jennifer to file a breach of contract action.The magistrate judge dismissed Jesse's petition to modify the spousal support due to a non-merger clause, which kept the spousal support provision outside the court's jurisdiction. Jennifer then sought partial summary judgment in district court, arguing that the Review Term was too vague to be enforceable. The district court agreed, striking the Review Term but upholding the rest of the spousal support provision under the agreement's severability clause. The jury found Jesse in breach of the agreement and awarded Jennifer $76,514 in damages, plus attorney fees and costs.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the Review Term was unenforceable due to its vagueness, indefiniteness, and uncertainty. The court also upheld the district court's application of the severability clause, maintaining the enforceability of the remaining spousal support provision. Jennifer was awarded attorney fees and costs on appeal as the prevailing party. View "Smith v. Smith" on Justia Law

James Wilson and Jillian Wilson, who were married and had one minor child, divorced, leading to a custody dispute. The magistrate court awarded primary physical custody to Jillian and allowed her to relocate with the child to Australia, where both hold citizenship. Jillian was also granted sole legal custody over educational and medical decisions, while James was given two weeks of visitation annually during school breaks. James appealed the decision.The magistrate court's decision was based on several factors, including the unhealthy relationship between James and the child, characterized by controlling and manipulative behavior. The court found that James's actions, such as co-sleeping and inappropriate touching, created an environment that could potentially harm the child. The court also considered Jillian's motivations for relocating, including better family support and higher income prospects in Australia.The Supreme Court of Idaho reviewed the case and affirmed the magistrate court's decision. The court held that the magistrate court did not abuse its discretion in allowing Jillian to relocate with the child, as the decision was supported by substantial and competent evidence. The court also found that the magistrate court correctly applied the legal standard for relocation and considered the best interests of the child.Additionally, the Supreme Court of Idaho upheld the magistrate court's decision to limit James's physical custody and visitation, as well as the award of sole legal custody to Jillian for educational and medical decisions. The court concluded that these decisions were in the best interests of the child and were supported by substantial evidence. Jillian was awarded attorney fees and costs on appeal. View "Wilson v. Wilson" on Justia Law

In 2014, Casey Moyer entered into an agreement with Doug Lasher Construction, Inc. for the construction and purchase of a new home, which was substantially completed in November 2014. Over the next six-and-a-half years, Moyer repeatedly informed Lasher Construction about issues with the home, particularly water leakage, and received assurances that the issues would be fixed. However, the problems persisted, and Moyer and Caitlin Bower filed suit against Lasher Construction in November 2021, alleging breach of contract and violation of the Idaho Consumer Protection Act.The District Court of the Fourth Judicial District of Idaho granted summary judgment in favor of Lasher Construction, ruling that all claims were time-barred under Idaho Code sections 5-241(b) and 5-216, which require that claims arising out of a contract for the construction of real property be brought within five years of the final completion of construction. The court also found that the Idaho Consumer Protection Act claims were time-barred under the two-year statute of limitations provided by Idaho Code section 48-619. The court rejected the homeowners' arguments for equitable estoppel and the repair doctrine, concluding that they failed to show that Lasher Construction prevented them from pursuing their claims within the statutory period.The Supreme Court of Idaho affirmed the district court's decision. The court reaffirmed that the repair doctrine is not available in Idaho and upheld the district court's conclusion that the homeowners failed to establish the elements of equitable estoppel. The court also agreed that the text messages and the July 2, 2021, response to the NORA demand did not constitute enforceable independent contracts. Lasher Construction was awarded attorney fees and costs on appeal as the prevailing party. View "Moyer v. Lasher Construction, Inc." on Justia Law

Tony Heath and Melissa Lish, neighbors in Chubbuck, Idaho, had a dispute after Heath parked two vehicles near Lish’s driveway. Lish, after Heath refused to move the vehicles, obtained a no parking sign from Denny’s Wrecker and had the vehicles towed. Denny’s refused to release the vehicles without payment. Heath sued Lish and Denny’s for civil trespass and conversion. The magistrate court granted summary judgment in favor of Lish and Denny’s and awarded attorney fees to Denny’s. Heath appealed, and the district court affirmed the magistrate court’s decisions.The Idaho Supreme Court reviewed the case. The court affirmed the district court’s decision regarding Denny’s summary judgment, holding that Denny’s actions were lawful under Idaho Code section 49-1806(1) and that Denny’s reasonably relied on Lish’s representations. The court found that Denny’s had no duty to verify the property line beyond Lish’s information and that Heath’s vehicles were towed lawfully. The court also affirmed the district court’s decision to reduce Denny’s attorney fee award, finding that the magistrate court did not need to address every factor in writing.However, the court reversed the district court’s decision regarding Lish’s summary judgment. The court found that genuine issues of material fact existed concerning whether there was boundary by acquiescence or boundary by agreement. The court noted that the declarations from previous property owners and the removal of part of the driveway by Lish’s husband raised questions about the boundary’s location and whether there was an agreement or acquiescence. The court remanded the case for further proceedings on Heath’s trespass and conversion claims against Lish.The court declined to award attorney fees on appeal to any party, noting that the issues raised were not pursued frivolously or without foundation. View "Heath v. Denny's Wrecker Service, Inc." on Justia Law