Justia Idaho Supreme Court Opinion Summaries

After a 21-year career as a firefighter with the City of Pocatello, Richard Nelson was diagnosed with leukemia. Nelson brought a workers’ compensation claim against the City. The Industrial Commission determined that the City failed to rebut a statutory presumption of causation with substantial and competent evidence. The City appealed, arguing there was substantial evidence to rebut the presumption that Nelson’s cancer was caused by his employment. The City also argued Idaho Code section 72-438(14)(b) unconstitutionally discriminated between the employers of firefighters who had cancer and the employers of other employees who claim to have contracted an occupational disease. After review, the Idaho Supreme Court affirmed the Industrial Commission. View "Nelson v. City of Pocatello" on Justia Law

This appeal stemmed from a family dispute concerning ownership interests in Nelsen Farms, LLC (“LLC”). The LLC, as originally established, included equal ownership for two of the Nelsen’s sons, Jack S. and Jonathan. However, in 2015, Jack H. Nelsen (“Jack H.”) and Joan Nelsen modified their estate plans and decided to pass their interests in the LLC to Jonathan via an inter vivos transfer, rather than through their wills. In August 2017, members of the LLC held a special meeting, during which the transfer of the membership interest to Jonathan was approved. The next month, Jack S., his wife and son, and Jack S.’s sister Janice Lehman, filed a complaint against Jack H., Joan and Jonathan alleging Jack H. and Joan were incompetent and lacked testamentary capacity to modify their 2015 wills and to make the 2017 inter vivos conveyance. Appellants also alleged Jonathan unduly influenced Jack H. and Joan to obtain the estate modification. Appellants amended their complaint in October 2017, adding a claim for dissolution of the LLC. The district court ultimately granted summary judgment to Respondents and dismissed all of Appellants’ claims. After review, the Idaho Supreme Court affirmed the district court in all respects save one: dissolution of the LLC. To this, the Court held that when the district court granted dissolution on summary judgment, Jack S. was ipso facto deprived of his membership interest and relegated to the status of economic interest holder, without the right to petition for dissolution since, under the statute, only members could do so. Jack S. was reinstated as a member of the LLC, and had the right to seek dissolution upon remand. View "Nelsen v. Nelsen" on Justia Law

The Idaho Industrial Commission appealed the dismissal of motion to renew a restitution order in a criminal case. The Owyhee County Prosecuting Attorney obtained an order of restitution against Malinda Poe in 2005, which required Poe to pay $2,346 to the Industrial Commission’s Crime Victims Compensation Program. In 2010, the Industrial Commission sought an order renewing the order of restitution, which was granted by the magistrate court. Five years later, the Industrial Commission sought another order renewing the order of restitution, which was also granted at that time by the magistrate court. In 2020, the Industrial Commission sought a third order renewing the order of restitution. This time, however, the magistrate court denied the request, finding that the Industrial Commission lacked standing to seek a renewal of the restitution order. The Industrial Commission appealed to the district court, which, sitting in its intermediate appellate capacity, also concluded the Commission lacked standing, and further concluded that the order of restitution was not subject to renewal pursuant to Idaho Code section 10-1110. The Industrial Commission appealed to the Idaho Supreme Court. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Idaho v. Poe" on Justia Law

In 2017, Ronald Van Hook was declared a vexatious litigant pursuant to Idaho Court Administrative Rule 59; this declaration was upheld by he Idaho Supreme Court. In 2021, “on behalf of his minor son” G.V.H., Van Hook filed a 28-page “Request for Leave to File Habeas Corpus and Juvenile Post-Conviction Relief” (“the Filing Request”). In the Filing Request, Van Hook alleged eight sets of “complaints” and asserted that numerous fundamental rights had been violated. He further requested a hearing on the Filing Request. Without holding a hearing on the matter, the district court denied the request because: (1) Van Hook, as a non-lawyer, could not engage in the unauthorized practice of law by representing his son in a civil court proceeding; (2) the petition for writ of habeas corpus was without merit; and (3) Van Hook was attempting to re-litigate prior court decisions that had been finally decided against him. Van Hook appealed, and the Supreme Court entered an Order Conditionally Dismissing Appeal, which stayed the proceedings, but allowed Van Hook time “to make application with the presiding district court judge permitting the notice of appeal to be filed, pursuant to I.C.A.R. 59(j).” The district court granted Van Hook permission to appeal “the narrow issue of whether [the district court’s] decision to deny Mr. Van Hook’s motion for leave to file litigation was arbitrary and capricious and/or in violation of his due process rights.” The Supreme Court withdrew its conditional order, allowing appeal on the narrow issue identified by the district court. As a matter of first impression, the Supreme Court first determined the proper standard of review to apply when reviewing a presiding judge’s denial of a vexatious litigant’s request to file new litigation pursuant to Rule 59(i) was the same standard used when reviewing a district court’s granting of a motion to dismiss pursuant to Rule 12(b)(6): “The issue is not whether the plaintiff will ultimately prevail, but whether the party is entitled to offer evidence to support the claims.” The Court found the district court did not err in denying Van Hook's request for leave to file new litigation, and his due process rights were not violated. View "Van Hook v. Idaho" on Justia Law

The case arose when four Micron Technology, Inc. employees filed a class action complaint against Micron in 2019, asserting violations of the Idaho Wage Claim Act. At the time, Micron had in place a compensation plan called the Incentive Pay Plan (IPP), in which eligible employees could earn yearly bonuses based on a number of performance metrics. The Employees alleged that the bonuses they received on November 23, 2018, for Micron’s 2018 fiscal year should have been greater. Micron moved for summary judgment, arguing that the Employees’ complaint was time-barred by Idaho Code section 45-614. Micron argued that section 45-614’s six-month statute of limitations applied to the Employees’ complaint because they sought “additional wages,” as opposed to “unpaid wages.” The district court granted Micron’s motion for summary judgment. The Employees timely appealed, arguing that the two-year statute of limitations applied. Finding no reversible error, the Idaho Supreme Court affirmed the district court's decision. View "Manning v. Micron Technology, Inc." on Justia Law

This case arose out of a dispute over provisions in a written contract for sewer drainage and treatment services between Groveland Water and Sewer District (“GWSD”) and the City of Blackfoot (“the City”). Individuals living outside city limits, or entities located outside city limits, but within GWSD, were required to sign a “consent to annex” form in order for the City to agree to connect them to sewer services. The dispute ultimately made its way to district court, where GWSD alleged that the City’s requirement violated GWSD’s jurisdictional sovereignty under Idaho Code section 42-3212. GWSD’s complaint against the City sought: (1) a declaratory judgment; (2) a finding of anticipatory breach of contract; and (3) injunctive relief. On motions from the parties, the district court granted GWSD’s request for preliminary injunction and for partial summary judgment on the anticipatory breach claim. After further motions, the district court granted summary judgment to GWSD on the remaining claims. The City appeals. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decisions. View "Groveland Water and Sewer Dist v. City of Blackfoot" on Justia Law

Christopher and Debra James appealed a district court order granting summary judgment in favor of the Idaho State Tax Commission (“Tax Commission”), reversing the decision of the Board of Tax Appeals (“BTA”). The district court affirmed the Tax Commission’s notice of deficiency decision, which disallowed a net operating loss carryback because the Jameses missed the deadline to claim the loss. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decision: Idaho Code sections 63-3072(e) and 63-3022(c)(2) required the Jameses to file their amended 2012 Idaho tax return by December 31, 2015, to carryback their 2014 NOL to the 2012 tax year. The Jameses failed to do so. View "Idaho State Tax Commission v. James" on Justia Law

Mother and Father married in 2016. In May 2020, Child was born in Utah County, Utah. Following Child’s birth, Mother and Father lived in Utah with Child until July 21, 2020, when Mother and Child relocated to Rigby, Idaho, without Father. Since July 21, 2020, neither Child nor Mother returned to Utah, although Father continued to live there. Father maintains that Mother expressed an intent to return to living in Utah by September 2020 and actively participated in searching for apartments with Father in Utah after she and Child moved to Idaho. Mother disputes that she ever expressed an intention to return to Utah after July 21. In October 2020, Father petitioned for divorce from Mother in Utah; the same day, he filed a motion for temporary orders seeking custody and visitation rights to Child. The Idaho magistrate court’s decision in this case indicated that Mother answered the Utah proceeding on December 10. Then, in February 2021, Mother petitioned for divorce from Father in Jefferson County, Idaho. After Father was served with Mother’s petition on February 12, he retained Idaho counsel to specially appear and contest Idaho jurisdiction. Subsequently, Father filed a motion to dismiss Mother’s petition for divorce for lack of jurisdiction under the UCCJEA, arguing that the Utah court had “home state” jurisdiction. The Utah court held oral argument on Father’s motion for temporary custody orders and Mother’s motion to transfer jurisdiction and issued its written order on April 12. Pertinent to this matter, the Utah court concluded that Utah was not an inconvenient forum and that Mother had stipulated in her answer that jurisdiction was proper in Utah. In May, the Idaho magistrate court heard oral argument on Mother’s motion to accept jurisdiction and Father’s motion to dismiss. Following the hearing, the Idaho magistrate court informally conferred with the Utah court about which state was the “more proper” home state, and concluded that the Utah court was the more appropriate jurisdiction to be the home state under the UCCJEA. The magistrate court entered a judgment on May 28, dismissing the Idaho proceeding. Mother appealed dismissal of her proceedings. But the Idaho Supreme Court determined the Idaho magistrate court did not err in denying Mother's motion to accept jurisdiction and dismissing her petition for divorce. View "Swanson v. Swanson" on Justia Law

Erick Pena filed a declaratory action against Viking Insurance Company of Wisconsin (“Viking”), alleging the automobile insurance policy he purchased was illegal because it provided illusory minimum limits of UIM coverage. Pena then filed a motion for summary judgment asking the court to declare that the UIM coverage was illusory. Viking filed a cross-motion for summary judgment, arguing that the policy was not illusory because it provided tangible benefits to a group of insured persons and that the offset provision in the policy complied with Idaho public policy. The district court granted Viking’s motion for summary judgment. Pena timely appealed. After review, the Idaho Supreme Court reversed, finding the policy at issue indeed provided illusory coverage. View "Pena v. Viking Insurance Company" on Justia Law

Taleetha Fuentes filed a worker's compensation complaint against her employer Cavco Industries and Cavco’s surety, Sentry Casualty Company (collectively, Defendants). Fuentes filed her complaint in July 2019, and the Defendants denied the claim. During discovery, the Defendants filed a motion to compel in October 2019, which was granted. Following no response from Fuentes, the Defendants filed a motion for sanctions, and Fuentes again did not respond. On December 19, 2019, the full Idaho Industrial Commission issued an Order Dismissing Complaint, citing Industrial Commission Judicial Rule of Procedure (JRP) 12(B). Five months later, in May 2020, Fuentes responded to the initial discovery requests and moved to retain the case on the active calendar, but her filing and motion were returned “unfiled” as explained in an email from the assigned Referee. Fuentes also moved for reconsideration of the dismissal and filed a petition to vacate the order of dismissal under JRP 15. The Commission denied both motions. The Idaho Supreme Court determined the Commission acted in excess of its powers when it misapplied JRP12(B) in the initial dismissal order, and in applying JRP 16 to Fuentes' case. Accordingly, the Court reversed the Commission’s decision to dismiss Fuentes’ case, and vacated the order. The case was remanded for further proceedings. View "Fuentes v. Cavco Industries, Inc." on Justia Law