Justia Idaho Supreme Court Opinion Summaries

BBC, LLC, contracted Germer Construction, Inc. to provide construction services for a subdivision development. A dispute arose regarding the amount owed, leading to arbitration as required by contract. The arbitrator awarded Germer nearly $1,000,000, including costs and fees. BBC sought a court order to vacate the arbitration award, while Germer requested confirmation of the award and entry of judgment. Germer also moved for a temporary restraining order and preliminary injunction, claiming BBC was dissipating assets. The district court granted an ex parte temporary restraining order restricting BBC’s asset transfers. At a hearing, the district court required BBC to post a $1,000,000 surety bond and Germer a $250,000 bond, characterizing them as “equivalent” to supersedeas bonds, then dissolved the restraining order and denied preliminary injunctive relief.BBC petitioned the Idaho Supreme Court for writs of prohibition or mandamus to vacate the district court’s order and prohibit further pre-judgment asset restrictions, arguing the district court lacked authority to require the bond or injunctive relief solely to secure a potential monetary judgment. The Idaho Supreme Court stayed the district court’s order and sought briefing from Germer and the Attorney General.The Supreme Court of Idaho held that the district court exceeded its authority by requiring BBC to post a surety bond to secure a potential money judgment for an unsecured debt. The court found no rule, statute, or inherent equitable power authorizing such relief in this context. The court issued a writ of review, vacating the district court’s order, including both bond requirements. BBC was found to have no adequate, speedy remedy at law, and the requested writs of prohibition and mandamus were denied. The case was remanded for further proceedings consistent with the opinion. View "BBC LLC v. LATAH COUNTY DISTRICT COURT" on Justia Law

The dispute centers on real property originally acquired by John and Constance Clark as part of a family farming operation. In 1988, two parcels were conveyed to their son, Jay Clark, who subsequently transferred the properties to Clover Hollow Farms, Inc., a corporation formed shortly before the conveyance with John Clark as its sole shareholder. Jay Clark served as vice-president and director of Clover Hollow. According to Jay Clark, his parents promised that Clover Hollow would hold the property in trust for him as a premarital asset, to be returned upon demand or subject to his exclusive control. Years later, Jay Clark assigned his interests in one of the properties to C & H Properties, LLC, operated by his children.After John Clark was placed under a conservatorship, the conservator, Judith Appleby, adopted corporate resolutions nullifying Jay Clark’s authority and authorizing the corporation to join litigation seeking a declaration that Jay Clark had no interest in the corporate stock, real property, or tangible property. Jay Clark filed counterclaims challenging the validity of these resolutions and seeking to regain title to the properties. The District Court of the Third Judicial District, Canyon County, granted summary judgment to the Estates and Clover Hollow. It ruled that judicial estoppel barred Jay Clark’s claims due to his failure to disclose the properties in bankruptcy and found that his claims under constructive trust, promissory estoppel, and unjust enrichment failed as a matter of law. The court also upheld the corporate resolutions enacted by Appleby.The Supreme Court of the State of Idaho reviewed the district court’s rulings. It held that Ms. Appleby, as executor, lacked authority under Clover Hollow’s bylaws and the Idaho Business Corporation Act to convene a special shareholder meeting and enact corporate resolutions, rendering those actions invalid. Consequently, Clover Hollow was never properly joined in the litigation. The Supreme Court vacated the judgment, reversed the grant of summary judgment on Jay Clark’s sixth counterclaim, and remanded the case with instructions to allow reasonable time for proper joinder of Clover Hollow as a party. View "Estate of Clark v. Clark" on Justia Law

Snap, a Delaware corporation, sued Vertical Raise, an Idaho LLC, and an individual, alleging tortious interference, misappropriation of trade secrets, and unfair competition. Liability was resolved in Snap’s favor on summary judgment. At trial, the jury awarded Snap $750,000 in unjust enrichment damages and $250,000 in punitive damages. However, the district court mistakenly entered judgment for $800,000, not $1,000,000. Snap sought an additur or new trial and discretionary costs. The district court granted both: costs were awarded, and the damages were increased via additur, but without giving Vertical Raise the option to accept or reject it.Vertical Raise appealed to the Supreme Court of Idaho, which in the prior case, Snap! Mobile, Inc. v. Vertical Raise, LLC, 173 Idaho 499, 544 P.3d 714 (2024), affirmed the costs award, reversed the grant of additur or new trial, and remanded with instructions to reinstate the jury verdict and enter an amended judgment accordingly. After remand, Vertical Raise’s surety bond paid the judgment and costs, but not post-judgment interest. Disputes arose over whether interest accrued from the dates of the original and amended judgments, or only from the post-remand judgment.In the present appeal, the Supreme Court of Idaho reviewed whether the district court erred by awarding post-judgment interest starting from the entry dates of the original and amended judgments. The Court held that post-judgment interest accrues from the dates when the original and amended judgments were entered, not from the date of the post-remand judgment, even if later judgments modify the amount owed. The Third Amended Judgment was affirmed. The Court also awarded Snap its attorney fees under Idaho Code section 12-121, finding Vertical Raise’s appeal unreasonable and without foundation. Costs on appeal were awarded as a matter of course. View "SNAP! MOBILE v. VERTICAL RAISE" on Justia Law

Bryan Smith requested court records from the Bonneville County District Court in April 2025, specifically seeking copies of judgments and certificates of service for 169 small claims cases. The Clerk’s Office charged him $352 for the records, relying on a 2017 Administrative Order that set fees for electronic records production. Smith paid the fee after the Clerk refused to reduce the charge, then filed suit against the Clerk in his official capacity, alleging he was overcharged and that Idaho Code section 74-102(10) should control the fee charged for electronic records. He sought declaratory relief and damages for the alleged overcharge.The Seventh Judicial District, Bonneville County, heard cross motions for summary judgment. The Clerk asserted quasi-judicial immunity based on following an administrative court order. The district court granted summary judgment for the Clerk, holding he had absolute quasi-judicial immunity and declining to address the merits of Smith’s claims, including whether the fee was excessive or inconsistent with Idaho law.The Supreme Court of the State of Idaho reviewed the appeal. Applying a de novo standard, the Court held that quasi-judicial immunity is only a defense to personal liability, not official capacity suits, and the district court erred in applying that defense. On the merits, the Court found the 2017 Administrative Order’s fee structure was inconsistent with Idaho Court Administrative Rule 32 and Idaho Code section 74-102(10), which require fees to reflect actual labor and material costs. Smith was overcharged by $330.67. The Supreme Court reversed the district court’s grant of summary judgment, vacated the amended judgment, and remanded with instructions to enter judgment in favor of Smith, directing the Clerk to refund $330.67 and awarding Smith costs on appeal. View "SMITH v. POULTER" on Justia Law

A dispute arose over ownership of a lakeside property in Sandpoint, Idaho, after Rhoda Shaw quitclaimed her interest in the property to her son, Bobby Shaw, in September 2021. Rhoda, elderly and experiencing cognitive issues, lived part-time in Arizona and Idaho. Her daughter, Cynthia Shaw Beck, later learned of the transfer and, concerned about Rhoda’s capacity, petitioned for and was appointed Rhoda’s guardian and conservator in Arizona in March 2022. Acting in that capacity, Cynthia filed a quiet title action and related claims in Bonner County, Idaho, seeking to invalidate the transfer to Bobby, alleging Rhoda lacked capacity and asserting fraud, and later attempted to add claims for undue influence and tortious interference.The Superior Court of Arizona, Cochise County, had already established Cynthia as Rhoda’s guardian and conservator, and subsequently issued orders retroactively determining Rhoda’s incapacity as predating the property transfer. Cynthia repeatedly sought to have the Idaho District Court either stay its proceedings or accept the Arizona court’s retroactive findings regarding Rhoda’s capacity as controlling. The District Court of the First Judicial District of Idaho denied these motions, finding that the Idaho litigation directly concerned the conveyance of Idaho property and that the Arizona guardianship proceeding did not address this specific issue. The Idaho court also denied Cynthia’s late motion to amend her complaint to add new claims and parties, citing undue delay and prejudice to defendants.The Supreme Court of the State of Idaho reviewed the appeal and affirmed the district court’s judgment. The court held that the Arizona guardianship court’s jurisdiction did not preclude Idaho courts from adjudicating the quiet title action concerning Idaho real property. The Idaho district court did not abuse its discretion in refusing to stay the case or enforce the Arizona court’s retroactive order, nor in denying Cynthia’s untimely motion to amend her complaint. No attorney fees were awarded on appeal, but costs were granted to respondents. View "SHAW v. SHAW" on Justia Law

Two unmarried individuals were in a long-term romantic relationship and jointly purchased real property in Idaho, with both names appearing on the purchase and sale agreement and the warranty deed. During their relationship, they lived together in California, and Bedell contributed to household expenses but not to rent or mortgage. After their relationship ended, Parsons attempted to quitclaim her interest in the Idaho property to a nonprofit, which then transferred it back to her. Bedell made the property his primary residence and filed suit seeking to quiet title in his name or, alternatively, to partition the property entirely to himself. Parsons counterclaimed, asserting she had a 50% interest and sought to quiet title in both names.The District Court of the Seventh Judicial District reviewed a series of summary judgment motions. It determined that Parsons had a 50% ownership interest in the property, relying on the presumption of equal shares when both parties’ names are on a deed without specified percentages, as set forth in Demoney-Hendrickson v. Larsen. The court found Bedell had not rebutted this presumption, ordered partition by sale, and awarded Parsons attorney fees. On reconsideration, the court maintained its conclusions, and later held that Bedell had waived any claim for contribution by not pleading it.The Supreme Court of the State of Idaho reviewed the case. It held that the district court erred by granting summary judgment to Parsons because genuine disputes of material fact existed regarding the parties’ intent about their respective ownership interests. The Supreme Court clarified that Idaho law does not preclude a co-tenant from having a 0% ownership interest, and the presumption of equal shares can be rebutted by evidence of the parties’ intent. The Supreme Court reversed the district court’s rulings on summary judgment, reconsideration, and attorney fees, but affirmed the finding that Bedell had waived any contribution claim. The case was remanded for further proceedings. View "Bedell v. Parsons" on Justia Law

A workplace accident in 2020 resulted in the death of Colby Eldon Johnson, who was using a self-unloading bed manufactured by SRM-Double L, LLC (“SRM”) on his employer’s truck. Colby’s father, Harry Johnson, filed suit against SRM and others, alleging products liability and negligence. During pretrial proceedings, Johnson failed to submit timely responses to SRM’s discovery requests and did not file his opposition to SRM’s summary judgment motion by the court-ordered deadline. He later filed late motions and exhibits, citing scheduling conflicts and unresolved discovery issues.The District Court of the Fifth Judicial District, Gooding County, granted SRM’s motions to strike Johnson’s untimely filings, finding no valid justification for the delay. Consequently, the court treated SRM’s summary judgment motion as unopposed and granted summary judgment in SRM’s favor, finding Johnson’s claims barred by Idaho statutes. The court also awarded attorney fees and sanctions against Johnson and his counsel under Idaho Rules of Civil Procedure 11 and 37, based on alleged misrepresentations and discovery delays.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision to strike Johnson’s untimely filings, finding no abuse of discretion. However, the Supreme Court reversed the grant of summary judgment, holding that the lower court failed to analyze whether SRM had met its burden under Rule 56(a), which is required even if the motion is unopposed. The Supreme Court affirmed the award of attorney fees under Rule 37 for discovery violations but reversed the sanctions under Rule 11 because the only support for the sanctions was inadmissible hearsay. The case was remanded for further proceedings on the merits. Attorney fees on appeal were denied, as no party had yet prevailed. View "Johnson v. SRM-Double L, LLC" on Justia Law

A group of Idaho cities, collectively known as the Coalition of Cities, hold junior ground water rights in the Eastern Snake Plain Aquifer (ESPA). These cities became involved in ongoing water rights litigation after the Surface Water Coalition (SWC), representing senior surface water right holders, initiated a delivery call in 2005. The SWC argued that junior ground water pumping reduced water availability for senior surface water users due to the hydrologic connection between the aquifer and the Snake River. This dispute led to a series of orders by the Director of the Idaho Department of Water Resources (IDWR) that established and modified the methodology for determining whether pumping by junior users caused material injury to senior rights.Following the issuance of the Fifth Amended Final Order (Fifth Methodology Order) and a subsequent Post-Hearing Order, the Director issued a Sixth Methodology Order, which superseded all previous orders. The Cities filed a petition for judicial review in the Snake River Basin Adjudication (SRBA) district court, challenging only the Post-Hearing Order (which addressed the Fifth Methodology Order) and not the operative Sixth Methodology Order. The district court affirmed the Director’s Post-Hearing Order, rejecting the Cities’ challenges to various factual findings and methodological choices.The Supreme Court of the State of Idaho reviewed the case. It concluded that it lacked jurisdiction to consider the Cities’ appeal because they failed to timely challenge the Sixth Methodology Order—the operative agency action currently in effect. As a result, the appeal was dismissed. The court awarded costs, but not attorney fees, to the IDWR and SWC, ruling that the statutory basis for attorney fees was inapplicable. The primary holding was that failure to timely appeal the operative final order deprived the court of jurisdiction to grant relief. View "City of Idaho Falls v. Department of Water Resources" on Justia Law

A worker died in an accident at a farm while apparently attempting to repair a connection between a truck and a piece of farming equipment. His father, on his own behalf and as representative of the worker’s estate, sued several parties, including the farm partnership, alleging negligence and other torts. The central issue was whether the farm partnership could be sued for tort damages, or whether Idaho’s Worker’s Compensation Law’s exclusive remedy rule barred such claims.The Fifth Judicial District Court, Gooding County, allowed the plaintiff to amend the complaint but denied his request to add a punitive damages claim. The farm partnership moved for summary judgment, arguing that the claims were barred by the exclusive remedy rule because the worker’s death arose out of and in the course of employment. The plaintiff opposed the motion, arguing that there were disputes of fact about employment status and whether the exception for “unprovoked physical aggression” applied, and also sought a continuance to obtain more discovery. The district court denied the continuance, excluded most of the plaintiff’s exhibits for lack of foundation or as inadmissible hearsay, considered the farm partnership’s exhibits, and granted summary judgment for the farm on the ground that the claims were barred by the exclusive remedy rule.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s denial of a continuance, exclusion of most of the plaintiff’s exhibits, and grant of summary judgment. The Supreme Court concluded that the plaintiff failed to create a genuine issue of material fact regarding the worker’s employment status or applicability of the statutory exception to the exclusive remedy rule. The Supreme Court found the district court erred in admitting certain defense exhibits, but the error was harmless and did not affect the outcome. The Supreme Court declined to award attorney fees on appeal and affirmed the district court’s judgment. View "Johnson v. Beadz Brothers Farms" on Justia Law

Elizabeth Miller filed for divorce from Mark Miller after a lengthy marriage in which Mark was a successful physician and Elizabeth was primarily a homemaker caring for their eight children. Following resolution of custody issues, the parties agreed to submit the remaining financial disputes to binding arbitration, with Elizabeth waiving her claim to spousal support. The arbitrator ultimately awarded Elizabeth 60% of the marital assets and retroactive child support, and required Mark to pay her remaining attorney fees. After the arbitrator amended the award to comply with Idaho law by removing post-majority child expenses, Mark challenged the validity of the arbitration award.The Magistrate Court of Ada County denied Mark’s requests to vacate or modify the award, finding that it had authority to refer the divorce action to arbitration under Idaho’s Uniform Arbitration Act (UAA), and confirming the arbitrator’s award. Mark appealed to the District Court of the Fourth Judicial District, arguing that Idaho Code section 32-715 gave the court exclusive jurisdiction over divorce matters, and that the arbitrator exceeded authority by awarding retroactive child support and an unequal asset division. The District Court rejected Mark’s jurisdictional challenge and affirmed the arbitration award, except for vacating the arbitrator’s award of attorney fees. The court awarded Elizabeth partial attorney fees on appeal, finding Mark had pursued the jurisdictional argument unreasonably.On further appeal, the Supreme Court of the State of Idaho affirmed the District Court’s ruling. The Court held that Idaho’s UAA authorizes courts to refer divorce actions to arbitration when the parties agree, and that nothing in Idaho Code section 32-715 prohibits this. The Court also determined the arbitrator had not exceeded the scope of authority. The Supreme Court upheld the award of partial attorney fees to Elizabeth for the district court appeal, and remanded the case for consideration of appellate attorney fees under Idaho Code section 32-704(3). View "Miller v. Miller" on Justia Law