Justia Idaho Supreme Court Opinion Summaries

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

Jared and Katherine Sommer brought a declaratory judgment claim against Misty Valley, LLC, after receiving written notice that the real estate developer planned to use an express easement across the Sommers’ land for access to a recently platted residential subdivision. The Sommers contended the planned use constituted an impermissible expansion of the scope of the easement, and brought a claim to terminate the easement. After a bench trial, the district court limited the use of the easement to the dominant parcel, which only included part of Misty Valley’s planned subdivision, and declined to terminate it. Misty Valley appealed the district court’s judgment, and the Sommers cross-appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Sommer v. Misty Valley, LLC" on Justia Law

Edward and Janice Easterling owned three contiguous parcels of real property in Ammon, Idaho. The Easterlings brought suit against Hal Pacific Properties, L.P. (“HAL”), claiming an easement by necessity over and upon HAL’s property in order to access their three merged parcels. Following cross-motions for summary judgment, a motion for reconsideration, and a short bench trial, the district court largely ruled in the Easterlings’ favor. The district court denied HAL’s affirmative defense that the Easterlings’ claims were barred by the statute of limitations. The district court further held that the Easterlings were entitled to an easement by necessity over and upon the HAL Parcel to allow access to all three of the Easterlings’ merged parcels. The district court placed the easement at the western border of the HAL Parcel and set its width at twenty-six feet. HAL appealed to the Idaho Supreme Court, contending the district court erred by denying its statute of limitations affirmative defense, granting the Easterlings’ claim for an easement by necessity for all three of their parcels, and improperly determining the location and width of the easement. The Supreme Court reversed the district court’s decision at summary judgment rejecting HAL’s statute of limitations defense under Idaho Code section 5-224. Because of this, the Court vacated the district court’s judgment and reversed its decisions that the Northern Parcel was entitled to an easement by necessity over the HAL Parcel; and that the width of the easement was set at twenty-six feet. The Supreme Court further reversed the district court’s decisions setting the location of the easement and granting an easement by necessity as to the Southern and Eastern Parcels over the HAL Parcel. The matte was remanded for further proceedings. View "Easterling v. Hal Pacific Properties, L.P." on Justia Law

Dennis and Sherrilyn Munden (the Mundens) and their limited liability company, Coyote Creek Ranch, LLC, purchased property in Bannock County, Idaho in 2012 (the Upper Property), and acquired adjoining property (the Lower Property) in 2014. The Mundens’ ranch was accessible by a gravel road (the Road) which left a paved public road before crossing the Lower Property. It then traversed a neighbor’s parcel to the Upper Property, before exiting to the north. The Mundens began ranching on the Lower Property in 2013 and started construction of a barn and living quarters on the Upper Property in 2015 after obtaining a three-year building permit. In 2017, the Mundens were informed by the Bannock County Commissioners that, pursuant to a 2006 county ordinance, the Road had been designated by the Commissioners for “snowmobile use only” between December 15 and April 15. All other vehicular use was prohibited during this timeframe. In January 2019, Bannock County passed an ordinance which gave discretion to the Bannock County Public Works Director (the Director) to determine when snowmobile trails would be closed to all but snowmobile use. Subsequently, the Director decided to close the Road for the 2018–19 winter season. The Mundens filed a complaint in district court against Bannock County, bringing several claims involving the Road, and obtained an ex parte temporary restraining order (TRO) to prohibit enforcement of the 2019 ordinance. The County moved to dissolve the TRO, which the district court granted. The district court then awarded attorney fees to the County. The Mundens amended their complaint to add their ranching operation, Coyote Creek Ranch, LLC, as a plaintiff, to which the County responded with an answer and counterclaim, alleging that the Road was a public right-of-way with no winter maintenance that had been designated as a snowmobile trail by the 2006 ordinance. The County then moved to dismiss the amended complaint for failure to state a claim. The district court granted this motion, concluding that because the claims turned on a legal determination of the Road’s status, the Mundens were required by Idaho Code section 40-208(7) to first petition for validation or abandonment proceedings with the Board of County Commissioners before they could bring a lawsuit. The district court accordingly entered a judgment dismissing the plaintiffs’ amended complaint in its entirety. Ultimately, the district court entered a judgment certified under IRCP 54(b)(1) authorizing an immediate appeal, and the Mundens timely appealed. The only error the Idaho Supreme Court found in review of this case was that the district court erred in issuing a writ of execution before there was a final appealable judgment. Judgement was affirmed in all other respects. View "Munden v. Bannock County" on Justia Law

Mike Von Jones (“Jones”) appealed the denial of his motion to set aside a sheriff’s sale and the award of attorney fees to Safaris Unlimited LLC (“Safaris”) under Idaho Code section 12-120(5). A jury found there was an enforceable contract between Jones and Safaris, and that Jones breached the contract. Safaris petitioned for and obtained a writ of execution requiring the sheriff to execute upon Jones’s personal and real property, including a pending lawsuit against Jeremy Sligar and Overtime Garage, LLC. At the sheriff’s sale, Safaris (the only bidder present) bought the lawsuit for $2,500.00 via a credit bid. Although Jones received notice of the sheriff’s sale, neither Jones nor his representative attended. Jones did, however, file a motion to set aside the sheriff’s sale of the Sligar Lawsuit. Then Safaris executed on additional personal property of Jones. The sale returned $8,300.00. While both Jones’s and Safaris’ appeals were pending, Jones tendered a $119,238.04 check to the clerk of the court in an attempt to satisfy the remainder of the amended judgment. The district court granted Safaris’ motion for release of funds and determined that the deposited funds were sufficient to satisfy the amended judgment. However, the district court found that the deposited funds exceeded the amount owed by $2,500.00 because Jones’s tender did not account for Safaris’ credit bid to purchase the Sligar Lawsuit. The district court held that Jones had not demonstrated a gross inadequacy of consideration because he failed to establish the litigation’s approximate value. Similarly, Jones failed to show very slight additional circumstances because he could not point to any procedural irregularities “pertaining to either the notice or conduct of the sale.” After denying Jones’s motion to vacate the sheriff’s sale, the district court ordered the clerk of the court to release the remaining $2,500.00 from the tender back to Jones or his attorneys. Jones timely appealed, arguing: (1) the district court erred by concluding Jones’s monetary tender to the clerk of the court did not preclude Safaris from claiming ownership of Jones’s pending lawsuit; (2) the district court abused its discretion by denying his motion to set aside the sheriff’s sale; and (3) the district court erred in awarding costs and fees pursuant to section 12-120(5) for actions taken after Jones’ tender to the clerk. Finding no reversible error, the Idaho Supreme Court affirmed the district court's orders. View "Safaris Unlimited, LLC v. Jones" on Justia Law

Appellants sued Respondents over alleged self-dealing and other purported breaches of fiduciary duty in the administration of a trust. Respondents argued that proceedings in Idaho were improper under the provisions of Title 15, chapter 7 of the Idaho Code (the “trust code”) because they alleged that the principal place of the Trust’s administration was in Indiana. The district court agreed and dismissed Appellants’ complaint. After review, the Idaho Supreme Court determined the district court erred in granting the motion to dismiss. Judgment was reversed and the matter remanded for further proceedings. View "Allen v. Campbell" on Justia Law