Justia Idaho Supreme Court Opinion Summaries

Daniel Genho and Riverdale Hot Springs, LLC had a dispute over payment for construction work Genho performed at Riverdale Resort. Genho was not a registered contractor at the start of the project but became registered midway through. Riverdale refused to pay Genho and prevented him from retrieving his tools and materials. Genho filed a Mechanic’s and Materialmen’s Lien and sued for breach of contract, unjust enrichment, quantum meruit, conversion, and to foreclose on the lien.The District Court of the Sixth Judicial District of Idaho granted Riverdale’s motion for a directed verdict on the breach of contract claim but denied it on the other claims. The court found that there were two separate transactions: one before and one after Genho became a registered contractor. The court allowed the jury to consider the unjust enrichment, quantum meruit, conversion, and lien foreclosure claims. The jury found in favor of Genho, awarding him $295,568, which was later reduced to $68,681. The district court also awarded attorney fees to Genho.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision in part and reversed it in part. The court held that equitable remedies are available under the Idaho Contractor Registration Act (ICRA) for work performed after a contractor becomes registered, provided the work is severable from the unregistered work. The court affirmed the denial of a directed verdict on the unjust enrichment, quantum meruit, and lien foreclosure claims but reversed the award of attorney fees for the conversion claim, as it was not based on a commercial transaction. The court also affirmed the award of attorney fees for the foreclosure action under Idaho Code section 45-513. Neither party was awarded attorney fees on appeal. The judgment was vacated and remanded for modification consistent with the opinion. View "Genho v. Riverdale Hot Springs, LLC" 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

John Gomez, Gilbert Hurtado, and Jesus Hurtado were members of G&H Dairy, LLC, which defaulted on its loans in 2013. To avoid bankruptcy, they negotiated with Wells Fargo and signed a Letter of Intent (LOI) to distribute G&H's assets among themselves. Gomez and Jesus Hurtado purchased the personal property assets and assumed portions of G&H’s debt, but they could not agree on the sales price for the real property. Gomez sued the Hurtado brothers and G&H for breach of contract, estoppel, unjust enrichment, and breach of fiduciary duty, and sought judicial dissolution of G&H. The Hurtados counterclaimed for damages and also sought dissolution.The District Court of the Fifth Judicial District of Idaho granted summary judgment for the Hurtados on Gomez’s breach of contract claim, ruling the LOI unenforceable, but denied summary judgment on the other claims. After a bench trial, the court ordered the dissolution and winding up of G&H and dismissed the remaining claims. Gomez appealed.The Supreme Court of Idaho affirmed the district court’s decision. It held that the LOI was unenforceable as it was an offer contingent on future agreements and lacked definitive terms. The court also found no breach of fiduciary duty by the Hurtados, as the LOI was unenforceable and the parties had not agreed on the real property transfer terms. The court dismissed Gomez’s quasi-estoppel claim, concluding that the Hurtados did not change their legal position since the LOI was not enforceable. The court also upheld the district court’s final accounting and winding up of G&H, finding no error in the characterization of transactions or member allocations. The court awarded attorney fees to the Hurtados, determining that Gomez’s appeal was pursued unreasonably and without legal foundation. View "Gomez v. Hurtado" on Justia Law

The case involves a dispute between Brian L. Porter, trustee of the Brian L. Porter Revocable Trust, and Marvin A. Remmich, manager of McMillan Storage LLC, an Idaho limited liability company. The conflict centers on the management of the LLC and the conduct of its members. Remmich initially filed a complaint in California against Porter, alleging various breaches related to the construction of the LLC’s storage facility. Porter later filed a complaint in Idaho, accusing Remmich of mismanaging the LLC. Both parties reside in California, and the LLC’s principal place of business is also in California.In the California action, the court denied Porter’s motion to dismiss on grounds of forum non conveniens, retaining jurisdiction over the case. Subsequently, the Idaho District Court dismissed Porter’s claims without prejudice under Idaho Rule of Civil Procedure 12(b)(8), which allows for dismissal when another action between the same parties for the same cause is pending. The district court reasoned that the California court could adjudicate the entire controversy, and concurrent litigation would lead to increased costs and potentially inconsistent judgments.The Supreme Court of Idaho affirmed the district court’s decision. It held that the district court did not abuse its discretion in dismissing the Idaho action. The court found that the parties and claims in both actions were essentially the same, and the California court was in a position to resolve the entire dispute. The court emphasized considerations of judicial economy, minimizing litigation costs, and avoiding inconsistent judgments. Consequently, the Idaho action was dismissed without prejudice, and Porter was directed to pursue his claims in the California court. View "Porter v. Remmich" on Justia Law

The case involves a failed business relationship between Mike Jones, Jeremy Sligar, and Sligar's business, Overtime Garage, LLC. Jones claimed they formed a joint venture in 2011 to buy and sell used vehicles, which Sligar disputed. The relationship deteriorated, and Sligar terminated the venture in 2016. Jones filed a complaint in 2016 seeking a declaratory judgment, dissolution of the joint venture, and other relief. Sligar counterclaimed for similar relief. During the litigation, Safaris Unlimited, LLC, bought Jones's interest in the case at a sheriff's sale and settled the case by dismissing Jones's claims against Sligar.The District Court of the Fifth Judicial District, Twin Falls County, denied Jones's motion to set aside the judgment in the first case (Sligar I) and granted summary judgment to Sligar in the second case (Sligar II), finding that Jones's claims were barred by res judicata. The court also awarded attorney fees to Sligar and Safaris, finding Jones's motion to set aside the judgment was frivolous and untimely. Jones appealed these decisions, arguing the consolidation of small claims actions with Sligar I was improper and that his Rule 60(b) motion was timely.The Supreme Court of Idaho affirmed the district court's decisions. It held that the consolidation of the small claims actions with Sligar I was proper, as the small claims were related to the disputed property in Sligar I. The court also found that Jones did not file his Rule 60(b) motion within a reasonable time, as he delayed over five months without a valid reason. Additionally, the court upheld the summary judgment in Sligar II, agreeing that Jones's claims were barred by res judicata. The court awarded attorney fees to Sligar for the appeal in Sligar I but not in Sligar II, as Sligar did not prevail on its cross-appeal. View "Jones v. Sligar" on Justia Law

This case involves a dispute between siblings Elizabeth and Jason Carter, who are both licensed dentists and co-owners of Carter Dental. In 2020, Jason accused Elizabeth of misusing the practice’s funds for her personal benefit. The parties agreed to mediation, which resulted in a settlement agreement that included a noncompete clause. Elizabeth later refused to sign a written mutual release, leading Jason to move to enforce the settlement agreement. The district court found the settlement agreement and noncompete clause enforceable and dismissed the case with prejudice. Elizabeth appealed, arguing that the noncompete clause and the settlement agreement were unenforceable.The Supreme Court of the State of Idaho affirmed the district court's judgments. The court found that Elizabeth was estopped from arguing that the settlement agreement was unenforceable because she had not appealed the district court’s dismissal of the case with prejudice. The court also held that the district court did not err in awarding attorney fees and costs to Jason and Carter Dental. The court concluded that Jason and Carter Dental were entitled to attorney fees and costs on appeal. View "Carter Dental v. Carter" on Justia Law

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

In a wrongful death action brought by Laura Milus on behalf of herself and her minor child against Sun Valley Company, the Supreme Court of the State of Idaho reversed the district court's grant of summary judgment to the defendant, Sun Valley. Ms. Milus' husband died after colliding with snowmaking equipment while skiing at Sun Valley Ski Resort. Ms. Milus alleged that Sun Valley breached its duties under Idaho Code section 6-1103(2) and (6), which require ski area operators to mark snowmaking equipment with visible signs or warning implements and place a conspicuous notice at or near the top of a trail or slope when snowmaking operations are being undertaken. The district court granted Sun Valley's summary judgment motion, concluding that Sun Valley had fulfilled its duty under section 6-1103(2) by marking the snowmaking equipment with yellow padding and did not have a duty under section 6-1103(6) because the snowmaking equipment was not actively discharging snow. However, the Supreme Court of the State of Idaho reversed the district court's decision, finding that the question of whether the yellow padding constitutes a warning implement under section 6-1103(2) is a question of fact for the jury. The court also held that section 6-1103(6) imposes a duty on ski area operators to place a conspicuous notice at or near the top of the trail or slope when snowmaking equipment is placed on the ski run or slope, regardless of whether the equipment is actively discharging snow. The case was remanded for further proceedings consistent with the court's opinion. View "Milus v. Sun Valley Company" on Justia Law

The Supreme Court of Idaho affirmed the lower court's decision that A.C. & C.E. Investments, Inc. (AC&CE) did not properly plead a derivative action and lacked standing to bring a direct claim in a lawsuit against Eagle Creek Irrigation Company (Eagle Creek). AC&CE, a shareholder of Eagle Creek, a nonprofit mutual irrigation corporation, challenged amendments made to Eagle Creek's bylaws and articles of incorporation that increased the number of capital shares the corporation was authorized to issue and removed a provision that Eagle Creek would hold all the water rights it acquired “in trust” for the benefit of its shareholders. AC&CE claimed Eagle Creek breached its fiduciary duty and requested that the district court declare the proposed amendments void. However, the district court concluded that AC&CE's complaint did not properly plead a derivative action, that AC&CE lacked standing to bring a direct claim, and that the amendments were validly adopted by a majority shareholder vote. The Supreme Court of Idaho affirmed these conclusions. The court also found that AC&CE's claim regarding the increase in the number of authorized capital shares was not ripe for adjudication because no additional shares had been issued. Finally, the court affirmed the lower court's denial of Eagle Creek's request for attorney fees. View "A.C. & C.E. Investments, Inc. v. Eagle Creek Irrigation Company" on Justia Law

Facing foreclosure, Ralph and Paula Isom entered into a deed in lieu of foreclosure agreement with Farms, LLC (“Farms”). The Isoms then leased the real property (a farm and various houses) back from Farms, subsequently defaulted on their obligations under the lease agreement, and filed a Chapter 11 bankruptcy, which was later converted to a Chapter 7. During the Isoms’ bankruptcy, Farms also acquired several third-party claims against the Isoms from other independent creditors of the Isoms. The bankruptcy court denied the Isoms a discharge, and after the bankruptcy case closed, Farms sued the Isoms personally, alleging three counts of breach of contract. Following a one-day bench trial, the district court awarded Farms a judgment of $1,281,501.68 as to Count III—related to Farms’ purchase of the third-party claims—but concluded that Farms’ remaining two claims related to the lease were barred by the applicable statute of limitations. The Isoms appealed, arguing the district court erred in determining the applicable statute of limitations as to Count III. Farms cross-appealed, arguing the district court erred in applying the statutes of limitation as to Counts I and II. After review, the Idaho Supreme Court affirmed the district court’s judgment as to Count III but reversed and vacated the judgment on Counts I and II. View "Farms, LLC v. Isom" on Justia Law