Justia Idaho Supreme Court Opinion Summaries

The case involves the Idaho Department of Health and Welfare's (the Department) action to set aside a transfer of real property from two Medicaid recipients, Robert Gilbert and Juanita Gilbert, to their five grandchildren. The Department had provided Robert and Juanita with Medicaid benefits totaling over $140,000. In 2005, Robert and Juanita executed two quitclaim deeds transferring their interest in real property to themselves and their grandchildren. After their deaths, the Department filed an action to set aside the two quitclaim deeds, alleging that the estates did not receive adequate consideration for the transfer of their interests in the real property. One of the grandchildren, Earle L. Beason, argued that the Department’s action was barred by the statute of limitations and that Robert and Juanita received adequate consideration for their interests in the property.The District Court of the Seventh Judicial District of the State of Idaho granted the Department’s motion for summary judgment and entered a judgment in favor of the Department setting aside the quitclaim deeds. The court concluded that the Department’s action was timely and that the Department had demonstrated the absence of a genuine issue of material fact regarding adequate consideration. Earle L. Beason appealed the decision.The Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that the Department’s action was timely filed pursuant to Idaho Code section 5-224, the catch-all statute of limitation, which provides a four-year limitation period when an action for relief is not otherwise provided for. The court also affirmed the district court’s grant of summary judgment in favor of the Department because Earle L. Beason did not establish a genuine issue of material fact regarding adequate consideration. View "Idaho Department of Health and Welfare v. Beason" on Justia Law

The case revolves around a premises liability claim filed by Diane Lands against Sunset Manor, LP, and Bingham County Senior Citizens Center, Inc. Lands tripped on an uneven sidewalk outside her apartment building, Sunset Manor, and suffered injuries including a concussion, headaches, chin pain, dizziness, and short-term memory loss. She claimed that her injuries were a result of the fall and sought damages for past and future medical expenses, non-economic damages, and other losses.The District Court of the Seventh Judicial District of the State of Idaho had previously reviewed the case. The court issued a scheduling order setting deadlines for disclosing expert witnesses and completing discovery. Lands failed to meet these deadlines, leading to the exclusion of her expert witnesses at trial. The district court also limited the time period for which non-economic damages could be recovered due to the lack of expert testimony.In the Supreme Court of the State of Idaho, Lands argued that her disclosure deadlines were automatically extended when the trial and pretrial conference were postponed. She also contended that the district court erroneously required non-retained experts to be disclosed at the same time and in the same manner as retained experts. The Supreme Court affirmed the decisions of the district court, ruling that Lands' disclosure deadlines were not extended and that any error in the district court's interpretation of the disclosure requirement for non-retained witnesses was harmless. The court also held that the district court did not err in limiting Lands' non-economic damages. View "Lands v. Sunset Manor, LP" on Justia Law

This case involves a medical debt collection claim between Medical Recovery Services, LLC (MRS), a debt collection service representing Franklin County Medical Center (FCMC), and Cierra Moser, a former FCMC employee. MRS sought to collect debt for medical services provided to Moser at FCMC during her employment. FCMC offered a 50% discount to employees for unpaid medical bills after insurance payments. When Moser's employment ended, FCMC allegedly retracted the discount and assigned the debt to MRS.The magistrate court granted partial summary judgment favoring MRS regarding a minimum principal amount of debt owed by Moser and decided in favor of MRS on the issue of FCMC's right to retract the employee discount. However, the district court reversed the partial grant of summary judgment and remanded all issues for retrial due to disputed facts requiring retrial.On appeal, MRS argued that the district court erred in reversing the partial grant of summary judgment and in remanding all issues for retrial. The Supreme Court of Idaho affirmed the district court's decision, finding that there was a material dispute of fact over the amount of medical debt owed by Moser, which precluded a grant of partial summary judgment. Furthermore, MRS failed to ensure relevant transcripts were included in the record on appeal to the Supreme Court, which was fatal to its position that the district court erred in remanding for a retrial on all issues. View "Medical Recovery Services v. Moser" on Justia Law

In this case, the Supreme Court of the State of Idaho was tasked with answering a certified question of law from the U.S. District Court for the District of Idaho. The question centered on the appropriate point of accrual for wage discrimination claims under the Idaho Human Rights Act (IHRA) and the Idaho Equal Pay Act (IEPA). Plaintiff Lori S. Blasch accused her former employer, HP Inc., of wage discrimination and retaliation under the IHRA and the IEPA.The Idaho Supreme Court held that the one-year limitation period for IHRA claims begins when the pay-setting decision is made and communicated to the employee. As for IEPA claims, the court determined that they are subject to the four-year statute of limitations outlined in Idaho Code section 5-224. Furthermore, the limitation period for IEPA claims begins to run when the employee receives each discriminatory paycheck. The court made these decisions after reviewing the language of the relevant statutes and considering previous court decisions, legislative intent, and public policy. View "Blasch v. HP, Inc." on Justia Law

The Supreme Court of the State of Idaho affirmed the judgment of the District Court of the Third Judicial District of the State of Idaho, Washington County, in a medical malpractice action brought by Vivian Nipper against Dr. Lore Wootton, M.D., Dr. Robert Mairs, D.O., and the Weiser Memorial Hospital District. Nipper alleged that she was injured during the delivery of her child via a cesarean section when Dr. Wootton negligently cut her bladder, causing significant damage. Dr. Mairs was called to assist in repairing the injury, but Nipper alleged his efforts also fell below the standard of care.After a significant period of discovery, both Dr. Wootton and Dr. Mairs moved for summary judgment on the claims asserted against them. In response to each motion, Nipper moved for Rule 56(d) relief, requesting additional time to respond. The district court denied both requests for Rule 56(d) relief and granted summary judgment in favor of Dr. Wootton and Dr. Mairs.The Supreme Court affirmed the district court’s denials of Rule 56(d) relief and subsequent grants of summary judgment. The Court found that Nipper failed to provide specific reasons why she could not present essential facts to oppose the summary judgment motion within the allotted timeframes. Further, the Court concluded that Nipper failed to set forth a satisfactory explanation for why, after two years, such essential evidence was not sought earlier. View "Nipper V. Wootton" on Justia Law

In an appeal from a property dispute in Ketchum, Idaho, the Supreme Court of the State of Idaho affirmed the lower court's judgment, in part, and vacated and remanded the case, in part, for further proceedings. The dispute arose when Trustees Glen Miller and Cynthia Anderson attempted to build a home on a lot they purchased in the Rocking Ranch No. 3 subdivision. The Rocking Ranch No. 3 Property Owners’ Association denied their application to construct the home and asserted several counterclaims to recover unpaid homeowners association (HOA) assessments. The district court granted summary judgment to the Association on Miller and Anderson’s claims and dismissed the Association’s counterclaims. On appeal, the Supreme Court of the State of Idaho affirmed the district court's dismissal of the Association’s counterclaims, concluding that the Association failed to establish its breach of contract counterclaim because it had not established two elements of the prima facie case: breach of the contract and damages resulting from the breach. The Supreme Court of the State of Idaho also vacated and remanded the district court's award of attorney fees to the Association for further proceedings, finding that the Association was not entitled to recover attorney fees for the counterclaims on which it did not prevail. View "Miller v. Rocking Ranch No. 3" on Justia Law

In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees. View "Worthington v. Crazy Thunder" on Justia Law

In this case, defendant Douglas Shane Thompson was convicted for domestic violence, and a no-contact order was put in place prohibiting him from contacting his minor son. Thompson appealed against the decision, arguing that there was no evidence that he posed a threat to his son and that the no-contact order violated his fundamental right to parent his son.The Supreme Court of the State of Idaho found that the lower court failed to provide adequate reasons for amending the no-contact order to prohibit all contact between Thompson and his son. The court concluded that the lower court did not exercise reason since it did not articulate any evidence that demonstrated a change in circumstances that justified the amendment of the no-contact order. It was also noted that the court did not explain what circumstances would need to change before Thompson could seek to reinitiate contact with his son.The court also observed that Thompson's argument that the no-contact order effectively terminated his parental rights was not sufficiently preserved for appeal. The court acknowledged the complexities when a judge not regularly dealing with family law issues has to analyze often competing interests involved.Therefore, the court reversed the decision of the lower court to amend the no-contact order and remanded the case back to the district court for further proceedings. View "State v. Thompson" on Justia Law

In this case, the Supreme Court of the State of Idaho was required to interpret aspects of Idaho’s mechanic’s lien statutes. Datum Construction, LLC, was the general contractor for a commercial construction project, and subcontracted part of the work to Elmore Welding and Steel, who rented equipment from RE Investment Co., LLC, dba Pro Rentals & Sales. Elmore Welding and Steel failed to pay Pro Rentals for the equipment rental, resulting in Pro Rentals filing a mechanic's lien. Datum then purchased a bond and petitioned the district court to release the lien. Pro Rentals did not oppose this petition and the district court released the lien. Datum argued that Pro Rentals had failed to begin proceedings to enforce its claim of lien within six months. The district court granted Datum’s motion to release the bond. Pro Rentals appealed this decision.The Supreme Court of the State of Idaho ruled in favor of Pro Rentals, determining that the district court had erred in applying a six-month statute of limitations from the mechanic’s lien statutes to a bond action. The court held that the bond replaced the lien, and the six-month period to enforce a lien was not applicable once the lien was released. The court determined that the appropriate statute of limitations for an action against the bond was two years under Idaho Code section 5-219. Therefore, the court reversed the district court’s decision to release the bond. View "Datum Construction, LLC v. Re Investment Co." on Justia Law

The holders of the second priority mortgage, Ray and Susan Montierth brought a foreclosure action against the holders of the first priority mortgage, Hendrik Dorssers and Justice Prevails, LLC, (collectively “Dorssers”), and a variety of other parties with an interest in the real property. In their pleadings, Dorssers asserted that their priority interest as the holder of the first priority mortgage still prevailed over all other encumbrances. In Dorssers view, a payment made by the debtor—years after the statute of limitations had run on the mortgage—revived the previously stale claim to foreclose their first priority mortgage and reinitiated the statute of limitations under Idaho Code section 5-238. However, on summary judgment the district court concluded that Idaho Code section 5-238 only applied when the payment was made prior to the lapse of the statute of limitations. Accordingly, the district court granted summary judgment to the Montierths after finding that no payment had been made by the obligor prior to the lapse of the statute of limitations and concluding that Dorssers’ mortgage was unenforceable as a matter of law. The district court subsequently denied Dorssers’ motion for reconsideration and objection to the proposed judgment. Thereafter, the district court entered a judgment and decree of foreclosure in favor of the Montierths, which specifically stated: “[t]hat the [Montierths’] lien interest is superior in time to all other parties’ liens, except the mortgage of Hendrik Dorssers and Justice Prevails, LLC, which is time barred and therefor [sic], unenforceable.” On appeal, Dorssers argue the district court erred: (1) in concluding that the partial payments did not extend the statute of limitations for enforcement of the first priority mortgage under Idaho Code section 5-238; (2) in the alternative, in concluding that a junior lien holder could quiet title to a senior lien holder; and (3) in issuing an order to quash the lis pendens they recorded after the appeal was filed. The Idaho Supreme Court reversed, finding the district court erred in its determinations: (1) to revive the statute of limitations the payment must have been made prior to the lapse of the statute of limitations; (2) the “transfer of money” was not a payment in recognition of the debt as a matter of law; and (3) the payment was not made by an obligor as a matter of law. In addition, the Court found the district court erred in striking the lis pendens. The matter was remanded for further proceedings. View "Montierth v. Dorssers" on Justia Law