Justia Idaho Supreme Court Opinion Summaries

In 2009, Joseph Pierce filed suit against Steven McMullen and Highland Financial, LLC, seeking damages for various violations of the Idaho Consumer Protection Act and for breach of contract, all based upon an alleged scam in which the Defendants represented that they could protect Pierce from losing his equity in real property that was facing foreclosure. Pierce alleged that the Defendants obtained title to his real property pursuant to a promise to assume the loans secured by the property, to market and sell the property, and to pay him at least $50,000 or more from the sale proceeds, depending upon the sale price. He claimed that he deeded the property to the Defendants, that they failed to make the payments on the loans, and that the property was sold at a foreclosure sale. The complaint also alleged that Highland Financial was the alter ego of McMullen. Defendants did not appear, and on August 6, 2010, the court entered default against them. Mr. Pierce filed his amended complaint on May 11, 2011. The complaint simply added allegations to support an award of punitive damages. On June 13, 2011, Mr. McMullen filed a notice of appearance on behalf of himself and on behalf of Highland Financial. McMullen filed an answer to the amended complaint in his behalf and on the behalf of Highland Financial. McMullen was not licensed to practice law in Idaho, therefore his appearance on behalf of Highland Financial and the answer he filed on its behalf were nullities. In his answer, McMullen only denied the allegations regarding punitive damages. The case was scheduled for trial to commence on June 18, 2012. Plaintiff appeared with counsel, but the Defendants again did not appear. After discussion with Pierce’s counsel, the district court stated that McMullen "is defaulted, his answer is stricken, and the plaintiff prevails on their [sic] claims," then asked Pierce to present evidence as to damages. Pierce testified as did another alleged victim of. McMullen. At the conclusion of the testimony, Pierce’s counsel filed proposed findings of fact and conclusions of law and a trial brief. The district court then issued its memorandum decision holding that. Pierce failed to prove any of his claims and ordered that his amended complaint be dismissed with prejudice. Pierce timely appealed. Largely because Defendants failed to appear and failed to answer the complaint and the facts of this case were therefore undisputed, the Supreme Court concluded that the district court erred in holding that Pierce did not prove his case. The case was remanded for further proceedings. View "Pierce v. McMullen" on Justia Law

Saint Alphonsus Diversified Care, Inc. (and others) formed a general partnership named MRI Associates. The parties executed a written partnership agreement (effective April 1985). The primary purpose of the partnership was to acquire and operate diagnostic and therapeutic devices, equipment, and accessories, beginning with a magnetic resonance imaging (MRI) scanner. MRI Associates and others formed two limited partnerships. One was named "MRI Limited Partnership," and it owned and operated an MRI scanner located on the hospital campus of Saint Alphonsus; the other limited partnership was named "MRI Mobile Limited Partnership," and it owned and operated mobile MRI scanners. For decades, a group of radiologists known as Gem State Radiologists had interpreted medical images pursuant to a contract that gave them the exclusive right to serve the radiological needs of patients of Saint Alphonsus. After the formation of MRI Associates, they interpreted MRI scans performed at MRI Center. In 1998, the Radiologists began planning to construct and operate an outpatient facility in Boise that was located away from the hospital. There were negotiations among the Radiologists, Saint Alphonsus, and MRI Associates to have one medical imaging entity, but those negotiations were unsuccessful. There was evidence that Saint Alphonsus was negotiating against MRI Associates with the Radiologists. In 1999, the Radiologists formed Intermountain Medical Imaging, LLC, (“IMI”), and a month later opened their facility. In 1998, Saint Alphonsus began negotiating with the Radiologists to partner with them in the imaging center. In 2001, Saint Alphonsus became a member of IMI. In 2002, IMI opened another facility in Meridian. In 2004, Saint Alphonsus gave notice to MRI Associates that it would dissociate from the partnership effective on April 1, 2004. Under the partnership agreement, Saint Alphonsus could not compete with MRI Associates for a period of one year. Saint Alphonsus then filed suit seeking to recover the value of its partnership interest from MRI Associates, and MRI Associates responded by filing a multi-count counterclaim and claims against third parties. The third-party claims were ultimately dismissed. The jury found Saint Alphonsus liable on all causes of action, and MRI Associates was awarded a judgment in the sum of $36.3 million. That judgment was vacated on appeal, and the case was remanded for further proceedings. The case was again tried to a jury. The district court submitted four claims for relief to the jury: breach of contract, intentional interference with a prospective economic advantage, breach of fiduciary duty, and civil conspiracy. The jury found in favor of the MRI Entities on each of the claims. Saint Alphonsus appealed, and the MRI Entities cross-appealed. Finding no reversible error, the Supreme Court affirmed the district court's judgment. View "St. Alphonsus Diversified Care, Inc. v. MRI Associates, LLP" on Justia Law

Appellant Charles DeGroot and DeGroot Farms, LLC appealed the district court's grant of summary judgment on its claims against Standley Trenching, Inc. d/b/a Standley & Co., relating to the construction and installation of a manure handling system at the DeGroot dairy. Beltman Construction, Inc., d/b/a Beltman Weldling and Construction, was the general contractor for the project. Beltman subcontracted with Standley for the installation of the manure handling equipment. J. Houle & Fils, Inc. manufactured the manure handling equipment installed at the DeGroot dairy. Because of maintenance problems with the manure handling equipment, DeGroot initiated litigation against Standley and Houle. DeGroot then initiated litigation against Beltman. Beltman brought a third party complaint against Standley. Standley counterclaimed against DeGroot for amounts due for parts and services. The district court granted Standley summary judgment on its counterclaim, granted Standley summary judgment on DeGroot's claims, and granted Standley summary judgment on Beltman's third party complaint. DeGroot appealed. Finding no reversible error, the Supreme Court affirmed. View "DeGroot v. Standley Trenching, Inc." on Justia Law

This appeal stemmed from the failure of Tamarack Resort, which was owned, developed, and operated by Tamarack Resort, LLC. The Resort was slated as a year-round community, complete with cross-country and downhill skiing, a championship golf course, hotel and conference facilities, retail shopping, restaurants, and lounges. Tamarack planned to offer a panoply of real estate options, including custom homes, condominiums, townhomes, chalets, and cottages. Construction at the Resort began in 2003. Housing units were built and sold, hotel facilities were developed, and by 2006, the ski areas, golf course, retail shops, and restaurants were up and running. In 2004, Tamarack hired Teufel Nursery as its landscape developer. Teufel provided landscaping services at the Resort from 2004 until early 2008. This appeal centered the priority of liens as between Teufel Nursery's mechanics lien and Credit Suisse's mortgages. The district court held that while Teufel had a valid and enforceable lien, it was inferior to Credit Suisse’s mortgages. On appeal, Teufel argues that such holding was in error and that the district court also erred in calculating Teufel's lien amount, interest, and attorney fees. Finding no error, the Supreme Court affirmed. View "Credit Suisse v. Teufel Nursery" on Justia Law

Appellant Edged in Stone, Inc. (EIS) sought damages for breach of contract, breach of warranty, breach of implied covenant of good faith and fair dealing, negligence and unjust enrichment when a skid loader it purchased experienced mechanical problems. The district court dismissed all of EIS's claims except breach of contract and unjust enrichment. Later, the district court entered a judgment in favor of Northwest Power Systems, LLC (NWPS), dismissing EIS's remaining claims and awarded NWPS attorney's fees and costs. EIS appealed to the Supreme Court, arguing arguing that the district court erred in granting summary judgment to NWPS. After careful consideration of the trial court record, the Supreme Court found no reversible error and affirmed that court's grant of summary judgment. View "Edged In Stone v. NW Power Systems" on Justia Law

Medical Recovery Services, LLC (MRS), a licensed collection agency, appeals from the district court’s order affirming default judgments entered by the magistrate court. Each Respondent’s account indebtedness was assigned to MRS. MRS filed suit to recover payment from each Respondent and also sought $350 in attorney fees from each, based on a contractual provision. None of the Respondents answered the complaints filed by MRS, so MRS filed for default judgments to be entered in each case. The magistrate court entered default judgments as to all Respondents but granted attorney fees in amounts less than the $350 that MRS was requesting under the contracts. MRS asserted that the magistrate erred in awarding attorney fees in the amount of the principal owed by the Respondents for medical services, as opposed to $350, which was the minimum amount that each Respondent contracted to pay. Finding no reversible error, the Supreme Court affirmed the district court. View "Medical Recovery Services v. Strawn" on Justia Law

Appellant Farmers National Bank (FNB) appealed the district court's grant of declaratory judgment in favor of Green River Dairy, LLC, and four commodities dealers: Ernest Carter, Lewis Becker, Jack McCall, and Hull Farms (Sellers). FNB argued the district court misinterpreted I.C. 45-1802 (a statutory lien provision) and as a result, erred in granting Sellers a priority lien on collateral securing a loan previously made by FNB. Upon review, the Supreme Court agreed with FNB about the misinterpretation and vacated the district court's grant of declaratory judgment in favor of the Sellers. View "Farmers Nat'l Bank v. Green River Dairy" on Justia Law

American West Enterprises appealed a district court's grant of summary judgement to Case New Holland, Inc. (CNH) in its effort to recover the cost of a remanufactured tractor engine CNH sold to a local seller that American West purchased. The district court dismissed American West's claim of implied warranty because there was no privity between American West and CNH. The district court also rejected American West's claims that it was an intended third party beneficiary of a contract between CNH and Pioneer and that Pioneer was an agent of CNH. American West appeals. The district court denied CNH's request for attorney fees and costs below. CNH cross-appealed. Finding no error, the Supreme Court affirmed all but the denial of attorney fees. The case was remanded to the district court for finding costs and fees in favor of CNH. View "American West Ent. v. CNH, LLC." on Justia Law

This appeal involves the transfer of the experience rating account for unemployment tax purposes from one employer to another pursuant to Idaho Code section 72-1351A(1)(a). After an investigation, the Department of Labor determined that the experience rating account of Diamond Z Trailer, Inc. (Diamond Z), which ceased operating in the spring of 2010, was transferred to Rule Steel Tanks, Inc. (Rule Steel), which hired the majority of the employees who were laid off by Diamond Z and which commenced marketing and manufacturing the same product that was manufactured by Diamond Z. Rule Steel appealed that determination. Finding no reversible error, the Supreme Court affirmed. View "Rule Steel Tanks, Inc. v. Dept of Labor" on Justia Law

BV Beverage Company, LLC appealed the dismissal of its petition regarding the expiration of its liquor license. Idaho Alcohol Beverage Control (ABC) contended that BV Beverage's interest in its license expired by operation of law when BV Beverage's lessee failed to timely renew. BV Beverage argued that the agency’s procedures deprived it of adequate procedural due process. The district court dismissed BV Beverage's petition because there was no agency action to review; even if there was agency action, the action did not violate procedural due process because BV Beverage had actual knowledge of the expiration date of the liquor license. Finding no reversible error, the Supreme Court affirmed. View "BV Beverage Company v. Idaho Alcohol Beverage Control." on Justia Law