Justia Idaho Supreme Court Opinion Summaries

A group of residents and an association challenged actions taken by the Harris Ranch Community Infrastructure District No. 1 (CID) in Boise, Idaho. The dispute arose after the CID’s board adopted resolutions in 2021 authorizing payments to a developer for infrastructure projects—such as roadways, sidewalks, and stormwater facilities—and issued a general obligation bond to finance those payments. The residents objected to the projects, arguing they primarily benefited the developer, imposed higher property taxes on homeowners, and allegedly violated the Idaho Community Infrastructure District Act (CID Act) as well as state and federal constitutional provisions. Previously, the District Court of the Fourth Judicial District reviewed the matter after the residents filed a petition challenging the board’s decisions. The district court ruled in favor of the CID and the developer, concluding most of the residents’ claims were either time-barred under the CID Act’s statute of limitations or had been waived because they were not preserved before the CID board. The court also found that the remaining claims failed on their merits, holding that the challenged projects qualified as “community infrastructure,” the stormwater facilities satisfied ownership requirements, and the CID was not the alter ego of the City of Boise. On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court clarified that, given the lack of formal administrative proceedings under the CID Act, the preservation doctrine did not apply to bar the residents’ arguments. Nonetheless, the Supreme Court held that any challenge to the CID’s original formation and the 2010 bond election was time-barred. The court further held that the roadways and stormwater facilities qualified as community infrastructure, the CID’s actions did not violate constitutional requirements regarding taxation or lending of credit, and the CID was not the alter ego of the city. The Supreme Court awarded costs on appeal to the CID and the developer but denied attorney fees to all parties. View "Doyle v. The Harris Ranch Community Infrastructure District No. 1" on Justia Law

A healthcare provider and several of its employees became involved in a dispute after the Idaho Department of Health and Welfare took protective custody of a child suffering from severe malnutrition. Following the hospital’s treatment of the child, a relative of the child, using media platforms and political organizations, publicly accused the hospital and its staff of participating in a conspiracy to kidnap, traffic, and harm children. These accusations led to public protests, threats, and disruptions at the hospital. The healthcare provider and its employees then sued the relative, his associates, and affiliated entities, alleging defamation, invasion of privacy, intentional infliction of emotional distress, trespass, and civil conspiracy, among other claims. They sought compensatory and punitive damages, injunctive relief, and removal of false statements.During proceedings in the District Court of the Fourth Judicial District, the defendant repeatedly failed to comply with discovery orders, missed depositions, and did not attend court hearings, despite multiple warnings and opportunities to comply. The court imposed escalating sanctions, culminating in striking the defendant’s pleadings and entering default as to liability. The court held a jury trial solely on damages, at which the defendant did not appear in person despite being given the opportunity. The jury awarded $52.5 million in compensatory and punitive damages, and the court issued a permanent injunction preventing further defamatory statements or harassment.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in imposing sanctions, entering default, and excluding evidence not properly disclosed. The court found that the defendant’s due process rights were not violated given repeated, willful noncompliance with court orders. The Supreme Court affirmed the district court’s judgment, including the damages award and the injunction, and awarded attorney fees and costs on appeal to the respondents. View "St. Luke's Health System, LTD v. Rodriguez" on Justia Law

Taylor L. Wood, her husband, and her son received medical care from physicians employed by Intermountain Emergency Physicians, PLLC (IEP). The resulting medical debt was assigned to Medical Recovery Services, LLC (MRS) for collection. After Wood’s attorneys alleged violations of state law, the Woods and IEP entered into a settlement that discharged the debt and provided payment to the Woods. Nevertheless, MRS later sued Wood to collect the same debt. Wood responded by counterclaiming and bringing IEP into the case as a third-party defendant, relying on the settlement agreement. MRS dismissed its complaint upon learning of the prior settlement, and all claims were eventually dismissed by the court.After judgment was entered, both sides sought a determination of the prevailing party and an award of attorney fees. The District Court of the Seventh Judicial District, Bingham County, found that Wood was the prevailing party over MRS and ordered MRS to pay Wood’s costs and attorney fees, concluding that MRS’s complaint was frivolous due to lack of proper investigation and communication regarding the settlement. MRS and IEP filed a first motion for reconsideration of the fees order, which was denied. They then filed a second motion for reconsideration, also denied, and subsequently appealed.The Supreme Court of the State of Idaho reviewed the case. It held that it lacked jurisdiction to review the district court’s order awarding costs and attorney fees to Wood because MRS and IEP’s notice of appeal from that order was untimely under Idaho Appellate Rule 14(a). The court did have jurisdiction to review the denial of the second motion for reconsideration, but because MRS and IEP failed to provide argument or authority on that issue, they waived it. The Supreme Court affirmed the district court’s denial of the second motion for reconsideration. View "Medical Recovery Services, LLC v. Wood" on Justia Law

Two siblings, Ryan and Nancy, disputed the administration of their father Hal’s estate and the status of his ownership interest in Tautphaus Park Storage, LLC (TPS), an Idaho storage facility business. Hal, who suffered from progressive dementia before his death, was TPS’s sole voting member and manager, with Nancy assisting in legal and management matters. Several amendments to TPS’s operating agreement changed ownership and management, culminating—after Hal’s death—in Nancy executing further amendments that retroactively transferred Hal’s economic interest to herself and changed accounting records. Nancy, an attorney, served as both Hal’s lawyer and later as personal representative of his estate. Ryan questioned whether Hal’s interest in TPS remained an estate asset and sought access to business records, which Nancy resisted.The siblings litigated issues in two related cases in Bonneville County: a probate case in the Magistrate Court regarding Hal’s estate, and a separate TEDRA (Trust and Estate Dispute Resolution Act) civil action in District Court initiated by Ryan. Both courts and parties at times treated the cases as consolidated. Ryan’s TEDRA complaint sought judicial determination of estate assets, breach of fiduciary duty, fraud, and appointment of a receiver, naming Nancy in both her individual and representative capacities and TPS as defendants. The magistrate court dismissed Ryan’s claims and removed Nancy and TPS as parties, finding that estate matters should be decided exclusively in probate. The district court affirmed, denying Ryan’s motions and dismissing his amended complaint, reasoning that Ryan’s claims were matters for probate only.On appeal, the Supreme Court of the State of Idaho vacated both lower courts’ judgments. It held that Ryan’s claims for judicial determination of estate assets and breach of fiduciary duty fall within TEDRA’s definition of “matters” and may be raised in a separate civil action, not only in probate. The Court reversed the orders dismissing claims and parties, remanded the case for further proceedings, and awarded costs and reasonable attorney fees to Ryan against Nancy personally. View "Monson v. Monson" on Justia Law

Noah Gilbert purchased a motor vehicle insurance policy from Progressive Northwestern Insurance Company, initially declining underinsured motorist (UIM) coverage but later adding a UIM endorsement with $25,000 per person and $50,000 per accident limits. The policy included an offset provision, reducing any UIM payout by amounts received from another party’s insurance. Gilbert paid premiums for this coverage but never filed a UIM claim or experienced an accident triggering such coverage. He later filed a putative class action, alleging that Progressive’s UIM coverage was illusory under Idaho law and asserting claims for breach of contract, breach of the implied covenant of good faith and fair dealing, unjust enrichment, fraud, and constructive fraud.The District Court of the Fourth Judicial District, Ada County, reviewed cross-motions for summary judgment. The court raised the issue of standing and ultimately held that Gilbert lacked standing because he had not filed a claim or been denied coverage, and thus had not suffered an injury-in-fact. Alternatively, the court found that Gilbert’s claims failed on the merits: there was no breach of contract or bad faith without a denied claim, no damages to support fraud or constructive fraud, and unjust enrichment was unavailable due to the existence of a valid contract. The court granted summary judgment for Progressive and denied Gilbert’s motion for class certification as moot.On appeal, the Supreme Court of the State of Idaho held that Gilbert did have standing, as payment of premiums for allegedly illusory coverage constituted a concrete injury. However, the Court affirmed the district court’s judgment, finding that Gilbert’s claims failed on the merits because he never filed a claim, was never denied coverage, and did not incur damages. The Court also affirmed the dismissal of the unjust enrichment claim, as an enforceable contract provided an adequate legal remedy. The judgment in favor of Progressive was affirmed. View "Gilbert v. Progressive Northwestern Insurance Co." on Justia Law

An employee suffered a severe hand injury, including the amputation of a finger, while operating a table saw without a safety guard at work. After receiving some worker’s compensation benefits, the employee filed a civil tort action against the employer, alleging that the employer’s requirement to use the saw without a guard constituted “willful or unprovoked physical aggression,” which, under Idaho law, would allow a lawsuit outside the worker’s compensation system. The employer did not respond to the lawsuit, and the employee obtained a default judgment for damages.Several months later, the employer moved to set aside the default judgment, arguing that the district court lacked subject matter jurisdiction because the employee’s worker’s compensation claim had been filed first. The District Court of the Fourth Judicial District agreed, stayed enforcement of the default judgment, and directed the parties to seek a determination from the Idaho Industrial Commission on whether the “willful or unprovoked physical aggression” exception applied. The Commission concluded that the exception did not apply, and the district court then set aside the default judgment and dismissed the civil action.On appeal, the Supreme Court of the State of Idaho held that the district court erred by deferring to the Commission on the applicability of the statutory exception and by setting aside the default judgment. The Supreme Court clarified that district courts have concurrent subject matter jurisdiction to determine whether the exception to the exclusive remedy rule applies, even if a worker’s compensation claim was filed first, unless the Commission has already decided the issue. The Supreme Court reversed the district court’s decision, vacated the Commission’s findings, and remanded with instructions to reenter the default judgment in favor of the employee. View "Tyler v. Masterpiece Floors, Inc." on Justia Law

The dispute centers on approximately 930 acres of agricultural land owned by two trusts near Pocatello, Idaho. The trusts entered into a purchase and sales agreement with a developer, Millennial Development Partners, to sell a strip of land for a new road, Northgate Parkway, which was to provide access to their property. The trusts allege that Millennial and its partners, along with the City of Pocatello, failed to construct promised access points and infrastructure, and that the developers and city officials conspired to devalue the trusts’ property, interfere with potential sales, and ultimately force a sale below market value. The trusts claim these actions diminished their property’s value and constituted breach of contract, fraud, interference with economic advantage, regulatory taking, and civil conspiracy.After the trusts filed suit in the District Court of the Sixth Judicial District, Bannock County, the defendants moved for summary judgment. The trusts sought to delay the proceedings to complete additional discovery, arguing that the defendants had not adequately responded to discovery requests. The district court denied both of the trusts’ motions to continue, struck their late response to the summary judgment motions as untimely, and granted summary judgment in favor of the defendants, dismissing the case with prejudice and awarding attorney fees to the defendants. The trusts appealed these decisions.The Supreme Court of the State of Idaho affirmed the district court’s denial of the trusts’ motions to continue, finding no abuse of discretion. However, it reversed the grant of summary judgment, holding that the district court erred by failing to analyze whether the defendants had met their burden under the summary judgment standard and appeared to have granted summary judgment as a sanction for the trusts’ untimely response. The Supreme Court vacated the judgment and remanded the case for further proceedings, and declined to award attorney fees on appeal. View "Rupp v. City of Pocatello" on Justia Law

Wil and Deborah Hansen, acting as grandparents and legal guardians of their grandchild J.L., paid tuition for J.L. to attend full-day kindergarten in Boise School District No. 1 during the 2017–2018 school year. The Hansens paid $2,250 for the second half of the kindergarten day, which they alleged violated the Idaho Constitution’s guarantee of free public education and constituted a taking of property without due process. In 2023, they filed a proposed class action seeking reimbursement and a declaration that the School District’s tuition policy was unconstitutional. The Hansens attempted to assert claims both in their own right and on behalf of J.L., arguing that J.L. was entitled to statutory tolling for minors under Idaho law.The District Court of the Fourth Judicial District, Ada County, dismissed the Hansens’ federal takings and state inverse condemnation claims as time-barred under the applicable statutes of limitation. The court found that only the Hansens, not J.L., had standing to pursue the claims, and that the two-year and four-year statutes of limitation for the federal and state claims, respectively, had expired. The court denied the Hansens’ motion for reconsideration, and the Hansens appealed.The Supreme Court of the State of Idaho affirmed the district court’s judgment. The Court held that J.L. lacked standing to assert a Fifth Amendment takings claim because he did not personally pay the tuition or suffer a deprivation of property, and there was no allegation that he was denied educational opportunities. The Court further held that the Hansens’ Fifth Amendment claim was time-barred under Idaho’s two-year statute of limitation for such claims, and the minority tolling statute did not apply. The School District was awarded costs on appeal. View "Hansen v. Boise School Dist #1" on Justia Law

Trevor Leon Moore pleaded guilty to misdemeanor battery, and the magistrate court entered an order withholding judgment, which included a requirement for Moore to complete a domestic violence evaluation. Moore objected to this requirement, arguing it was improper since he pleaded guilty to simple battery, not domestic battery. The magistrate court's order was file stamped on December 14, 2023, and Moore filed a notice of appeal to the district court on January 26, 2024, challenging only the evaluation requirement.The district court addressed the intermediate appeal and affirmed the magistrate court's order, including the disputed requirement. Moore then filed a timely notice of appeal to the Supreme Court of Idaho.The State filed a motion to dismiss Moore's appeal, arguing that his notice of appeal from the magistrate court to the district court was untimely, rendering the district court's decision void. The Supreme Court of Idaho agreed that the district court's decision was void due to the untimely appeal but clarified that it still had jurisdiction to review the district court's decision. The court held that it could not grant Moore the relief he sought because the district court lacked subject matter jurisdiction to grant any relief on intermediate appeal.The Supreme Court of Idaho vacated the district court's decision, dismissed the appeal to the Supreme Court, and remanded the case to the district court with instructions to dismiss Moore's intermediate appeal as untimely. View "State v. Moore" on Justia Law

Claudia Horn worked for Insure Idaho, LLC for over six years and signed a non-solicitation agreement prohibiting her from soliciting Insure Idaho customers. After leaving Insure Idaho to work for Henry Insurance Agency, LLC, several Insure Idaho customers followed her. Insure Idaho sought a preliminary injunction to prevent Horn and Henry Insurance from soliciting its customers, which the district court granted. The district court later found Horn in contempt for violating the preliminary injunction when another former Insure Idaho customer moved its business to Henry Insurance.The district court granted the preliminary injunction and found Horn in contempt, but did not impose any sanctions. Henry Insurance was dismissed from the contempt proceedings and awarded attorney fees. Horn appealed the contempt judgment, and both Henry Insurance and Insure Idaho cross-appealed.The Supreme Court of Idaho reviewed the case and determined that the district court erred in finding Horn in contempt, as it lacked the ability to impose any sanction. The court also found that the district court misinterpreted the term "solicitation" and that Horn's actions did not constitute solicitation under the plain meaning of the term. The court held that the district court abused its discretion by granting the preliminary injunction without adequately addressing whether Insure Idaho was likely to succeed on the merits of its claims.The Supreme Court of Idaho reversed the judgment of contempt, vacated the preliminary injunction, and remanded the case for further proceedings. The court affirmed the district court's dismissal of Henry Insurance from the contempt proceedings and awarded attorney fees to Henry Insurance. The court also awarded Horn attorney fees for the contempt trial and appellate attorney fees for both Horn and Henry Insurance. View "Insure Idaho v. Horn" on Justia Law