Justia Idaho Supreme Court Opinion Summaries

This was a case of misappropriation of trade secrets case arising out of a dispute between two competing businesses providing spa and salon services in Pocatello: La Bella Vita, LLC (La Bella Vita) and Eikova Salon and Spa, LLC (Eikova). In February 2011, a number of employees left their employment at La Bella Vita to open Eikova, a new salon nearby. La Bella Vita brought suit alleging that these employees took its confidential client information to create and promote Eikova. After conducting discovery, La Bella Vita voluntarily dismissed all of the defendants except Amanda Shuler and Eikova, as well as all of the claims except the violation of the Idaho Trade Secrets Act and breach of the confidentiality agreement. On motion by the remaining defendants, the district court granted summary judgment against La Bella Vita on these remaining issues. La Bella Vita appealed the district court’s decision to strike a supplemental brief offered in opposition to summary judgment, and also argued that disputed issues of material fact should have precluded the entry of summary judgment. Upon careful consideration of the specific facts of this case, the Supreme Court concluded the district court improperly granted summary judgment in favor of Eikova and Shuler, and remanded the case for further proceedings. View "La Bella Vita v. Shuler" on Justia Law

TracFone Wireless, Inc. was a non-facilities-based commercial mobile radio service provider (a pure wireless reseller) that provided prepaid wireless telecommunications services. It desired to be designated as an eligible telecommunications carrier (ETC), which would permit TracFone to provide wireless telecommunications services to qualified low-income consumers and to receive money from the Universal Service Fund to subsidize such services. In 2004, TracFone filed a petition with the Federal Communications Commission asking that it forbear from the statutory requirement that an ETC must provide services, at least in part, over its own facilities. The Commission granted the forbearance, subject to specific conditions, including the requirement that TracFone "must have direct contact with the customer." In 2010, TracFone filed a petition with the Idaho Public Utilities Commission (PUC) seeking designation as an ETC, pursuant to 47 U.S.C. 214(e)(2). The PUC initially denied the petition on the ground that it would not serve the public interest because TracFone was not paying the fees required by the Idaho Telecommunications Service Assistance Program and the Idaho Emergency Communications Act. TracFone appealed to the Supreme Court. But while that appeal was pending, the PUC staff and TracFone agreed to a settlement under which TracFone would pay the fee required by the Telecommunications Service Assistance Program and it would file a declaratory judgment action seeking a judicial determination of whether it was required to pay the fee required by the Emergency Communications Act. The PUC accepted the stipulation and issued an order approving it on May 18, 2012. In June of that same year, TracFone filed this suit against the State of Idaho and the Idaho Emergency Communications Commission (collectively "State") seeking a determination that TracFone was not required to remit an emergency communication fee. The district court's judgment simply stated who prevailed. In its memorandum decision, the court stated, "Section 31-4802(13)(d) applies to Tracfone [sic], making it a ‘telecommunications provider' and thus subject to the Act's fee-collection duty." Assuming that was its intended declaratory judgment, the Supreme Court affirmed the judgment on appeal. View "Tracfone Wireless v. Idaho" on Justia Law

This appeal arose from three mechanic’s liens that Keith Sims, dba Kasco of Idaho, LLC (“Sims”) filed on property that Dan Jacobson, Sage Holdings, LLC, Steven G. Lazar, the Mitchell A. Martin and Karen C. Martin Family Trust, and Devon Chapman (collectively “the Jacobson group”) had an interest in. The district court granted summary judgment to the Jacobson group on Sims’s lien foreclosure and quantum meruit claims. The court also awarded the Jacobson group their attorney fees and costs. Sims appealed the district court’s (1) grant of summary judgment on the lien foreclosure; (2) denial of a continuance at the quantum meruit hearing; and (3) award of attorney fees. Sims later withdrew his appeal on the lien foreclosure and continuance issues, so the only issue remaining was the district court’s grant of attorney fees to the Jacobson group. Finding no reversible error with regard to the fees issue, the Supreme Court affirmed the district court’s award. View "Sims v. Jacobson" on Justia Law

In 2009, Mosell Equities filed this action against Berryhill & Company and Mr. and Mrs. Berryhill (collectively "Berryhill"). The complaint alleged that Mosell Equities had loaned money to Berryhill and that it had failed to repay the loans. The case was tried to a jury in September 2009. During the trial, Messrs. Mosell and Berryhill provided widely divergent testimony regarding their relationship, whether the checks were actually loans, and what had transpired. The jury returned a verdict in favor of Berryhill on the claims regarding the alleged loans. Mosell Equities filed a motion for a judgment notwithstanding the verdict or, in the alternative, for a new trial. The district court granted a judgment notwithstanding the verdict as to part of a claim for relief, and the Supreme Court reversed that order on appeal. On remand, the district court granted Mosell Equities a new trial, and Berryhill appealed. After review, the Supreme Court reversed: by granting the motion for a new trial in order to enable Mosell Equities to try the case on a theory it did not raise in the first trial, the district court abused its discretion by failing to act consistently with the applicable legal standards. The district court was directed to enter judgment consistent with the original jury verdict. View "Mosell Equities, LLC v. Berryhill & Co., Inc" on Justia Law

Franklin Building Supply Co., Inc. (“FBS”) filed suit against Aaron Michael Hymas to recover money owed on an open account for construction supplies, equipment, and labor supplied to Crestwood Construction, Inc. FBS claims that Hymas guarantied any unpaid balance on Crestwood’s account. The district court granted FBS’s motion for summary judgment. Shortly thereafter, the district court permitted FBS to correct an error in an affidavit submitted in support of summary judgment regarding the amount of interest owed on the outstanding balance. Hymas twice moved the court to reconsider its order granting summary judgment and the district court denied both motions. He timely appealed. Finding no reversible error, however, the Supreme Court affirmed. View "Franklin Building Supply Co. v. Hymas" on Justia Law

Cable One, Inc., is a Delaware corporation headquartered in Phoenix, Arizona. In 2005, Cable One received business income from four types of activities in Idaho: cable television services, internet access services, advertising services, and cable modem leasing. In its Idaho income tax return for that year, it included revenues earned from all of those activities except revenues from providing internet access services to Idaho customers. It excluded those revenues on the ground that providing such services to customers in Idaho constituted Arizona sales, although it also excluded such revenues from its 2005 Arizona income tax return on the ground that they came from Idaho sales. In 2008, the Idaho Tax Commission issued a notice of deficiency determination asserting a tax and interest deficiency on Cable One for the 2005 tax year. Cable One petitioned for redetermination, which the Tax Commission denied. Cable One then filed a complaint in the district court, which tried the matter de novo, and ruled in favor of the Tax Commission. Cable One then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Cable One, Inc. v. Idaho State Tax Commission" on Justia Law

This appeal stemmed from the sale of dairy cattle that were subject to Appellant Farmers National Bank’s (FNB) perfected security interest and Respondent J&M Cattle Company’s (J&M) agister’s lien. The net sale proceeds received from the sale of the dairy cattle were insufficient to satisfy both FNB’s perfected security interest and J&M’s agister’s lien. J&M filed an action for declaratory relief to resolve FNB’s and J&M’s competing interests. Although FNB’s perfected security interest had a priority date that predates J&M’s lien, the district court determined that J&M’s lien had priority over FNB’s perfected security interest. The district court entered a final judgment in favor of J&M, and FNB appealed. Finding no reversible error, the Supreme Court affirmed the district court's decision. View "J&M Cattle Co v. Farmers National Bank" on Justia Law

This appeal stemmed from a 1983 Ground Lease of over four acres of property in Pocatello which Quail Ridge Medical Investors, LLC leased from Pocatello Hospital, LLC (d/b/a/ Portneuf Medical Centers, LLC (PMC)). Quail Ridge appealed a declaratory judgment which held that PMC was entitled to an adjustment in the annual rent owed by Quail Ridge from $9,562.50 annually to $148,500 annually, and that Quail Ridge was obligated to pay PMC $416,812.50 in rent for the period of 2010 to 2012. Finding no reversible error, the Supreme Court affirmed. View "Pocatello Hospital v. Quail Ridge Medical Investor" on Justia Law

This case was a permissive appeal of an order denying the appellants' motions for summary judgment. The central issue was whether an attorney who, as counsel for a corporation, issued an opinion letter stating that a stock redemption agreement did not violate the law, could be held liable to the shareholder whose stock was redeemed if the opinion was incorrect and the redemption agreement was later declared void as violating state law. The Supreme Court held that the claim against appellant Richard Riley was barred by res judicata and that there could be a claim against the remaining appellants where the opinion letter was addressed to respondent and stated that he could rely upon it. View "Taylor v. Riley" on Justia Law

This was a dispute between two collections agencies. Medical Recovery Services, LLC (MRS) and Bonneville Billing and Collections, Inc. (BBC) both had outstanding accounts relating to the same debtor, Stacie Christ. In 2008, MRS obtained a judgment against Christ for $1,868. MRS then obtained an order for continuing garnishment of Christ's wages at her place of employment, Western States Equipment Company (WSEC), until the judgment, plus interest, was satisfied. WSEC intended to make the first payment on the continuing garnishment, but a WSEC's payroll department employee inadvertently selected "BBC" instead of "BCS," (for Bonneville County Sheriff), on a computer dropdown menu, and sent the first payment of $331.00 to BBC. WSEC repeated the same mistake on two subsequent occasions and sent checks for $394.83 and $357.38 to BBC instead of the Bonneville County Sheriff. BBC had been assigned two accounts involving Christ as the debtor. The first account was assigned on May 7, 2007, in the amount of $325.50. BBC filed a complaint in connection with this account on May 8, 2008, but did not obtain a judgment. The second account was assigned on April 24, 2008, in the amount of $966.86, and BBC had not yet initiated legal efforts to collect on this account. Due to WSEC's payroll mistake, BBC received three checks from WSEC: $331.00 on July 22, 2008; $394.83 on July 28, 2008; and $357.38 on August 12, 2008. In total, WSEC mistakenly sent BBC $1,083.21, which BBC applied to Christ's outstanding accounts. MRS received a letter from the Bonneville County Sheriff alerting MRS to WSEC's errors. The letter indicated that WSEC had also notified BBC of the error but that BBC refused to return the money. After learning of WSEC's payroll mistake, MRS contacted WSEC and instructed WSEC to discontinue the garnishment. MRS sent BBC a demand letter asking for a return of the $1,083.21. BBC acknowledged receiving the checks and stated that it intended to keep the funds since Christ owed on accounts held by BBC. BBC further indicated that, at the time the checks were received, it believed that the funds resulted from wage assignments that Christ had voluntarily initiated to pay her debts. MRS then sued BBC alleging conversion, unjust enrichment, and requesting a constructive trust over the disputed funds in the amount of $1,083.21. Both parties moved for summary judgment. The magistrate court denied MRS' motion, granted BBC's motion, and awarded BBC attorney fees and costs in the amount of $10,658. On May 3, 2011, MRS appealed to the district court. The district court reversed the magistrate court's judgment and: (1) granted MRS summary judgment on the issues of unjust enrichment and conversion; (2) imposed a constructive trust in favor of MRS over the disputed $1,083.21; (3) vacated the magistrate court's order granting BBC attorney fees and costs; (4) remanded the matter to determine a pre-appeal attorney fee award for MRS; and (5) granted MRS attorney fees on appeal. BBC appealed. The Court of Appeals reversed the district court and reinstated the magistrate court's award of attorney fees. Upon review, the Supreme Court concluded the district court erred in finding that BBC was unjustly enriched by MRS, erred in finding that BBC converted MRS' property, and erred in imposing a constructive trust. Accordingly, the district court's memorandum decision and order was reversed. The case was remanded to the district court with instructions to reinstate the magistrate court's award of attorney fees in favor of BBC and to determine an appropriate award in favor of BBC for attorney fees incurred in proceedings before the district court on intermediate appeal. View "MRS v. Bonneville Billing and Collections" on Justia Law