Justia Idaho Supreme Court Opinion Summaries

After the roof collapsed on Lakeland True Value Hardware, LLC's (Lakeland) store, Lakeland sought payment for business personal property and business income losses from its insurer, The Hartford Fire Insurance Co. (Hartford). Lakeland filed suit, asserting bad faith and breach of contract. The district court granted summary judgment dismissing the bad faith claim for lack of evidence. The breach of contract claim proceeded to trial, and the jury returned a verdict in favor of Hartford. On appeal, Lakeland challenged the order granting summary judgment. Lakeland also asserted: (1) the jury was confused as to the period of coverage and the district court's evidentiary rulings and jury instructions relevant to that issue were erroneous; (2) the jury verdict was not supported by substantial and competent evidence; and (3) that the district court erred by awarding discretionary costs to Hartford. Finding no error, the Supreme Court affirmed. View "Lakeland True Value Hardware v. The Hartford Fire Insurance Co." on Justia Law

The issue on appeal before the Supreme Court was a challenge to the failure of a district court to give preclusive effect to a California federal district court judgment during a proceeding to grant recognition of a subsequent German judgment. Plaintiff Ron Markin executed a promissory note in 1988 agreeing to pay Defendant Thomas Grohmann $551,292.00 with interest at ten percent per annum. The loan was for a business transaction between the parties. In September 1997, Plaintiff sued Defendant in the United States District Court in the Central District of California in order to collect the promissory note. At that time, Defendant resided in Scottsdale, Arizona. The parties entered into a written settlement agreement to resolve the lawsuit. The agreement provided the principal and interest owing; that the lawsuit would be dismissed if that sum plus interest was paid according to the terms of the agreement; that the court would retain jurisdiction to enforce the agreement; that if the amount due under the agreement was not paid in full as provided in the agreement, Plaintiff could obtain a judgment as provided by California law; and that the agreement "shall be governed by and interpreted under the laws of the State of California." Defendant failed to pay according to the agreement, and Plaintiff obtained an ex parte judgment against Defendant. After learning that Defendant owned real property in Germany, Plaintiff commenced a civil action in Germany to enforce the California judgment. The German trial court dismissed the action on the ground that the judgment was not enforceable under German law. Plaintiff appealed and asserted that if the judgment was not enforceable, he could recover on the settlement agreement upon which that judgment was based. The appellate court agreed, and it issued an opinion ordering Defendant to pay Plaintiff. The court held that it could enter a judgment against Defendant based upon the settlement agreement because he had previously been a German citizen. Upon its review of matter, the Idaho Supreme Court concluded that the German judgment was a final judgment under German law. But because the German judgment did not recognize the effect of a final judgment under California law, it conflicted with the California judgment. The Idaho Court therefore reversed the judgment of the district court that recognized the German judgment. View "Markin v. Grohmann" on Justia Law

A jury returned a special verdict that: (a) awarded damages against an attorney and his girlfriend based upon the jury's finding that they had breached their fiduciary duties to a former client of the attorney by purchasing half of his stock in a closely held corporation for less than its fair market value; and (b) cancelled debts owing by the corporation to the attorney and his girlfriend based upon the jury's finding that they had breached their fiduciary duties to a shareholder, the former client's widow, by making loans to the corporation. The district court granted a new trial on the ground that there was insufficient evidence to justify the verdict, and this appeal followed. Finding sufficient evidence to support the jury's verdict, the Supreme Court affirmed the grant of a new trial. View "Berry v. McFarland" on Justia Law

The issue on appeal to the Supreme Court concerned Appellant Daniel Fuchs appeal of a district court's decision which found that the Director of the Idaho State Police Alcohol Beverage Control (ABC) had properly exercised his discretion when he ruled that neither party had been a prevailing party for the purposes of attorney fees. Fuchs was issued a Retail Alcohol Beverage License and subsequently opened Aubrey's House of Ale (Aubrey's) in Coeur d'Alene. The Alcohol Beverage Control Bureau Chief conducted an unannounced inspection of the premises. After this inspection, ABC filed a Complaint for Forfeiture or Revocation of Retail Alcohol Beverage License regarding Fuchs's license. Eventually, the parties filed cross motions for summary judgment in the action before an ABC hearing officer. After oral argument, the hearing officer granted summary judgment to Fuchs. On appeal to the Director of the ABC, the Director did not order Fuchs' license revoked because of confusion surrounding the proper interpretation of the applicable rule under which Fuchs was cited. The Director's Final Order addressed the hearing officer's erroneous application of quasi-estoppel and Fuchs' unsuccessful arguments regarding improper rulemaking and claim that the agency acted arbitrarily. The Director denied attorneys' fees to both parties, declaring neither was the prevailing party because neither acted without a reasonable basis in fact or law. Upon review, the Supreme Court agreed that Fuchs was not a prevailing party and affirmed the district court's decision to deny fees. View "Fuchs v. Idaho State Police" on Justia Law

This appeal arose from a products liability action brought by Jesus Hurtado and John Reitsma, d/b/a J & J Calf Ranch (J & J), against Land O'Lakes, Inc. (Land O'Lakes). J & J alleged that the Land O'Lakes milk replacer it used to feed its dairy calves was defective and caused the death of more than one hundred calves. A jury found in favor of J & J and awarded damages. Land O'Lakes appealed, arguing that the district court improperly admitted expert testimony and that J & J failed to prove both liability and damages. Land O'Lakes petitioned the Supreme Court to vacate the judgment of the district court and enter judgment in its favor or, alternatively, to vacate the judgment and order a new trial. J & J cross-appealed the district court's award of attorney fees, arguing that the court abused its discretion by excluding fees incurred before and during previous litigation in this matter. J & J petitioned the Supreme Court to vacate the award of attorney fees and remand with instructions to include attorney fees accrued in the first trial in its calculation of reasonable attorney fees. Upon review, the Supreme Court affirmed, holding that Land O'Lakes waived issues regarding expert testimony. The Court affirmed the jury verdict because it was supported by substantial competent evidence and affirmed the district court's award of attorney fees because it properly exercised its discretion. View "Jesus Hurtado v. Land O' Lakes, Inc." on Justia Law

This case arose from a dispute regarding the sewer system serving Sunnyside Industrial Park, LLC. Sunnyside Park Utilities (SPU) provides water and sewer services to the industrial park and Doyle Beck and Kirk Woolf are, respectively, the Secretary and President of SPU. Printcraft Press, Inc. (Printcraft) is a printing business that occupies a building in the industrial park. In 2004, Printcraft entered a ten-year lease for property in the industrial park. The dispute in this case centered on the failure of Beck, Woolf, and SPU to disclose limitations on the sewage system, including the amount of sewage the system could handle and its lack of suitability to dispose of some chemicals used in the printing business. After Printcraft started using the sewage system, SPU disconnected Printcraft from the system in December 2006. Printcraft sued SPU, Beck, and Woolf (collectively, defendants) for breach of contract, fraudulent nondisclosure, and fraud. At trial, the jury found that the defendants owed Printcraft a duty to disclose the limitations of the system and failed to do so. The trial court denied the defendants' motion for judgment notwithstanding the verdict (JNOV) and entered judgment in favor of Printcraft. Defendants timely appealed and Printcraft cross-appealed. However, in 2009, SPU filed a renewed motion for relief from judgment under Idaho Rule of Civil Procedure 60(b), asserting newly discovered evidence regarding whether Printcraft's damages claim was affected by its subsequent connection to the Idaho Falls city sewer system. The district court found that the newly discovered evidence satisfied the requirements of I.R.C.P. 60(b) and granted a new trial on the issue of damages. On appeal, the defendants argued that they had no duty to disclose, that any failure to disclose did not lead Printcraft to believe any fact that was false, that the refusal to give SPU's requested jury instructions was improper, and that the district court erred in denying their motion for JNOV because there was not sufficient evidence to support the jury's determination of damages. In turn, Printcraft's cross-appeal argued that the district court erred in limiting the potential bases for defendants' duty to disclose, that Printcraft's breach of contract claim was improperly dismissed, that the subsequent Rule 60(b) motion was improperly granted, that the issue of punitive damages should have been submitted to the jury, and that the judge erred in denying Printcraft's request for attorney fees. Upon review, the Supreme Court reversed the district court's grant of SPU's motion under 60(b)(2). The Court affirmed the denial of defendants' motion for JNOV as to the existence and breach of a duty to disclose and as to the amount of damages. The Court found that the district court did not abuse its discretion in excluding the jury instructions. And the Court affirmed the district court's decision to deny Printcraft's request to put the question of punitive damages to the jury. View "Printcraft Press, Inc. v. Sunnyside Park Utilities, Inc." on Justia Law

Petitioner Tanner Mickelsen appealed the grant of summary judgment in favor of Respondent Broadway Ford, Inc. on his complaint that alleged fraud in the inducement. Petitioner asked for a rescission of the contract between the parties based on that alleged fraud or alternatively on mutual mistake. Petitioner leased a truck from Broadway Ford. The truck had over 1400 miles on it, but was sold as new and under factory warranty. The truck had been modified with a six-inch suspension lift and four oversized tires. Though he purchased the truck in Idaho Falls, Petitioner resided in Moses Lake, and took the truck to his local dealership for repairs. In the first year of the lease, Discovery Ford made several repairs to the vehicle under the warranty. But when Petitioner took the truck back to Discovery Ford for "handling problems," the service manager advised Petitioner that these repairs would not be covered by the warranty because of the lift modifications made to the truck's suspension. Broadway Ford told Petitioner that they would try to resolve the issue if Petitioner drove or shipped the truck to Idaho Falls. Petitioner did not take the truck back to Idaho Falls or ship it there. He eventually stopped making lease payments and voluntarily surrendered the truck to the bank who provided the financing. Finding that the district court made no error in granting summary judgment in favor of Broadway Ford, the Court affirmed that court's decision. View "Mickelsen v. Broadway Ford, Inc." on Justia Law

This appeal arose from Gaylen Clayson's attempt to purchase a restaurant and cheese factory in Thayne, Wyoming. Prior to making a formal offer on the property, Clayson was granted access to the property in order to begin operating the restaurant and refurbishing the factory. His effort to purchase the subject property ultimately failed, and Don Zebe and Rick Lawson subsequently purchased the property. Clayson then filed a breach of contract action against Zebe and Lawson, alleging the existence of both express and implied contracts entitling Clayson to compensation for the pre-purchase work Clayson had performed on the property. The district court partially granted Zebe and Lawson's motion for summary judgment, holding that there was no express contract between the parties. After a bench trial, the district court determined that the parties' conduct created both implied-in-fact and implied-in-law contracts, which required Zebe to reimburse Clayson for costs he incurred while working on the subject property. Zebe appealed, arguing that the district court erred because Zebe neither requested Clayson's performance nor received any benefit as a result of Clayson's work on the property. Zebe asked the Supreme Court to vacate the judgment of the district court and remand the matter for entry of judgment in their favor. Upon review, the Supreme Court found that assignment was silent as to consideration. It did not address whether Clayson was to be reimbursed for the expenses he had previously incurred or whether the assignment was a gratuitous act by Clayson. Therefore, the Court held that the district court did not err in finding an implied-in-fact contract. View "Clayson v. Zebe" on Justia Law

This appeal arose from an action brought by Stonebrook Construction, LLC against Chase Home Finance, LLC where it sought to foreclose a mechanic's lien. The district court granted Chase's motion for summary judgment, holding that Stonebrook was precluded from placing a lien against the subject property because it did not properly register under the Idaho Contractor Registration Act (ICRA) Stonebrook appealed, arguing that Chase lacked standing to assert this defense and was not within the class intended to be protected by the ICRA. Alternatively, Stonebrook contended that the good-faith registration of one member of the LLC constituted actual or substantial compliance with the requirements of the ICRA. Upon review of the matter, the Supreme Court affirmed: "the plain language of the Act unambiguously indicates that the Legislature intended to require all limited liability companies engaged in the business of construction to register as contractors and to preclude those that do not register from enforcing mechanic's liens. Although the result for Stonebrook is harsh, it is the result the Legislature intended. [The Court was] not at liberty to disregard this legislative determination as to the most effective means of protecting the public." Thus, the Court declined to vacate the district court’s decision. View "Stonebrook Construction, LLC v. Chase Home Finance, LLC" on Justia Law

Defendant Roberta Shore retained attorney third-party Defendant Nicholas Bokides to represent her in her divorce from William Shore. Pursuant to the divorce decree, William took all interest in the couple's business, Bear River Equipment, Inc., a farm equipment dealership. Roberta had instructed Bokides to provide notice to McCormick International USA, Inc, a Bear River creditor, that she would no longer personally guarantee its advances. Bokides never provided the notice, and McCormick sued Roberta to enforce the guarantee. Roberta brought a third party complaint against Bokides for malpractice. Bokides did not deny the malpractice claim, but alleged that Roberta failed to mitigate her damages because she did not seek to enforce the divorce decree’s mandate that William hold her harmless from all Bear River debts. Bokides appealed the trial court's judgment in Roberta's favor. Roberta cross-appealed the district court's determination that her damages were limited to advances made after entry of the divorce decree. Upon review of the matter, the Supreme Court affirmed: "substantial and competent evidence in the record supports the district court's finding that Roberta reasonably concluded that William was judgment proof and that it would therefore be futile to enforce the divorce decree against him. An implicit corollary of that finding is the finding that McCormick could not successfully seek compensation from William. Thus substantial, competent evidence supports the district court’s determination of the extent of Roberta's damages." View "McCormick International USA, Inc. v. Shore" on Justia Law