Justia Idaho Supreme Court Opinion Summaries

Off-Spec Solutions LLC was a trucking company located in Nampa, Idaho, that was formed by two brothers: Christopher and Daniel Salvador. The Salvadors sold 51 percent of their ownership interest in Off-Spec Solutions to Transportation Investors LLC. To implement the transaction, the Salvadors and Transportation Investors entered into a purchase agreement and an LLC agreement. The purchase agreement identified “The Central Valley Fund II” and “The Central Valley Fund III” as affiliates of Transportation Investors. Off-Spec Solutions also entered into separate employment agreements with the Salvadors. The purchase agreement stated that all disputes concerning the agreement would be governed by California law. After disputes arose between the parties, Off-Spec Solutions petitioned an Idaho district court to compel the Salvadors to arbitrate claims relating to the employment agreements in Idaho instead of California. The Salvadors subsequently filed a cross-application with the district court seeking to compel Off-Spec Solutions and Transportation Investors and its affiliates to arbitrate all claims between the parties in a consolidated arbitration in Idaho. While those applications were pending, Transportation Investors and its affiliates filed a petition with a California Superior Court seeking to compel the Salvadors to arbitrate all claims arising from the purchase agreement and the LLC agreement in Sacramento County, California. The questions this case presented for the Idaho Supreme Court’s review were: (1) whether a forum selection clause was unenforceable under California law if enforcement would contravene a strong public policy of the forum where suit is brought (in this case, Idaho); and, if yes, then (2) whether the forum selection clauses at issue must be invalidated based on the public policy set forth in Idaho Code section 29-110(1). The Supreme Court held California law required an examination of the public policy of the forum in which suit was brought, and that the forum selection clauses at issue violated the strong public policy of the State of Idaho. The Court affirmed the district court’s ruling that claims arising from the parties’ purchase agreement and LLC agreement had to be arbitrated in Idaho. View "Off-Spec Solutions LLC v. Transportation Investors LLC" on Justia Law

St. Luke’s Meridian Medical Center (St. Luke’s) provided inpatient hospital care for an indigent patient from January 26, 2016, until March 9, 2016. St. Luke’s sought payment from the Board by submitting a medical indigency application. In September 2016, the Board issued an initial determination, only approving payment from January 26 through February 2, 2016. St. Luke’s appealed the denial. The Board amended its determination by only partially extending payment approval through February 18, 2016. St. Luke’s petitioned for judicial review. In October 2017, the district court affirmed the Board’s decision. St. Luke’s appealed to the Idaho Supreme Court, and the Supreme Court held that the Board’s findings did not provide a reasoned analysis, as required by the Idaho Administrative Procedures Act (IDAPA). The case was remanded back to the Board for it to make the required findings of fact and conclusions of law. On remand, the Board entered its findings of fact, conclusions of law, and order, again denying payment and finding that the services provided were not the most cost-effective services as required under the Idaho Medical Indigency Act. St. Luke’s again filed a petition for judicial review, and the district court again affirmed the Board’s decision. Once more, St. Luke’s timely appealed. The Idaho Supreme Court determined the Board’s decision reflected a misinterpretation of the definition of “medically necessary services;” the Board’s decision was set aside and the matter remanded for further proceedings. View "St. Luke's Health System v. Board of Commissioners of Gem County" on Justia Law

An indigent patient was admitted to St. Alphonsus Regional Medical Center (St. Alphonsus) on October 7, 2017, and continued to receive treatment in the hospital until she was discharged on January 12, 2018. During her stay, St. Alphonsus filed a third-party medical indigency application on her behalf, and later filed two additional requests for payment of services. The Board of Ada County Commissioners (the Board) approved payment for dates of service from October 7 until October 10, 2017, but denied payments for services provided from October 11 until December 31, 2017, relying on the opinion of the Ada County Medical Advisor that the services provided on those dates were not “medically necessary” under the definition in Idaho Code section 31-3502(18)A(e). St. Alphonsus appealed the Board’s initial determination, but the final determination upheld the denial for payment beyond October 11. Upon St. Alphonsus’ petition, a district court reversed the Board’s decision, finding that the services “currently available” to a patient were to be considered as a “necessary medical service.” The Board argued “there did exist options for the Patient to proceed to rehabilitation at a facility other than St. Alphonsus, but for the Patient’s lack of funding.” Furthermore, the Board asserted that Idaho Code section 31-3502(18)A(e) is unambiguous in that “[t]here is no wording in [sub]section (e) of the statute that limits the ‘most cost-effective services’ to services that the Patient can afford to pay for.” After review, the Idaho Supreme Court determined the Board exceeded its statutory authority in denying St. Alphonsus reimbursement for providing medically necessary services. “The Board’s denial of payment was not based on substantial evidence and prejudiced St. Alphonsus’ substantial right to compensation for services rendered to an indigent patient.” View "St. Alphonsus Regional Medical v. Ada County" on Justia Law

TRC Fabrication, LLC, (TRC) purchased steel tubing from Brown Strauss Steel Co. (Brown Strauss), a company located in Fontana, California. Under the sales contract, Brown Strauss sold the tubing “free on board” to TRC. Brown Strauss contracted with Jay Transport, a trucking company based in Rigby, Idaho, which in turn engaged Dale Kelly, an independent owner-operator of a semi-truck to transport the tubing. Kelly hauled the tubing to Idaho Falls and delivered the load to TRC. When employees of TRC began to unload the tubing from the trailer, a forklift operator dropped the steel tubing, which then slid across the pavement and struck Kelly, seriously injuring his right leg, ankle, and foot. Kelly and his wife Nancy filed a complaint against TRC, seeking to recover damages for negligence and loss of consortium. After TRC filed a motion seeking summary judgment, the district court granted the motion and dismissed the Kellys’ complaint. The district court concluded that Idaho’s worker’s compensation law extended statutory immunity to TRC and limited the Kellys’ recovery to workers’ compensation benefits. The question this case presented for the Idaho Supreme Court's review was whether the immunity afforded a statutory employer applied to TRC to bar the Kellys' complaint for damages. The Supreme Court reversed the district court’s order granting summary judgment, vacated the judgment entered, and remanded the case for further proceedings: the district court erred in concluding that TRC was Kelly’s category one statutory employer. View "Kelly v. TRC Fabrication LLC" on Justia Law

This case presented the Idaho Supreme Court with a fundamental, but previously unanswered, question: what duty is owed by a hospital to someone who is on its premises solely to visit one of its patients? Summary judgment was entered against Victor Dupuis in a premises liability case brought against a hospital, Eastern Idaho Regional Medical Center. Dupuis was visiting his hospitalized wife in January 2017 when he slipped and fell on ice in the hospital’s parking lot. Dupuis sued the hospital, alleging inadequate snow and ice removal in the parking lot caused him to fall. Dupuis argued that the hospital had breached the duty of care it owed to him as an invitee. The district court granted the hospital’s motion for summary judgment, holding that Dupuis was a licensee, and the hospital did not have superior knowledge of the dangerous conditions over that of Dupuis, and, therefore, the hospital did not breach any duty owed to Dupuis. Dupuis appealed, arguing the district court erred in determining that he was a mere licensee, rather than an invitee, and that even if he were a licensee, the hospital assumed and subsequently breached a duty of care to keep the property in reasonably safe condition. The Supreme Court found Dupuis was an invitee, thereby reversing the district court’s grant of summary judgment, vacating the judgment entered, and remanding the case for further proceedings. View "Dupuis v. Eastern Idaho Health Services Inc." on Justia Law

Mary Clare Griffin purchased a bottle of Italian wine, which broke in her hands as she attempted to open it, causing substantial injuries. Griffin and her son, a minor who witnessed the event, brought a product liability suit against Zignago Vetro S.P.A. (Zignago), the Italian manufacturer of the wine bottle; Marchesi Antinori SRL (Antinori), the Italian wine company that purchased the bottle from Zignago, filled it with wine, and exported it to the United States; Chateau Ste. Michelle Wine Estates, Ltd. (Ste. Michelle), the United States importer; S & C Importers and Distributors, Inc. (S&C), the Idaho distributor who purchased the bottle from Ste. Michelle; and, Albertson’s LLC (Albertson’s), the retailer that sold the bottle to Griffin. Zignago successfully moved the district court to dismiss Griffin’s complaint based on a lack of personal jurisdiction. Griffin appealed the district court’s decision, asking the Court of Appeal to apply the personal jurisdiction framework established by World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980). Griffin also appealed the district court’s order granting summary judgment to Antinori and Ste. Michelle on the grounds that Griffin failed to meet her burden to show a prima facie case for a product liability claim. Additionally, Griffin appealed several adverse discovery rulings. The Idaho Supreme Court found the correct test when determining personal jurisdictional issues remained the “stream of commerce” test adopted by the United States Supreme Court in World-Wide Volkswagen. Applying that test to the case here, the Court reversed the district court’s decision to grant Zignago’s motion to dismiss for lack of personal jurisdiction and remanded the case for further proceedings. The Court affirmed the district court’s decision granting Antinori’s and Ste. Michelle’s motions for summary judgment, finding it did not abuse its discretion in failing to grant Griffin’s motion to compel discovery against Antinori and Ste. Michelle. View "Griffin v. Ste. Michelle Wine Estates LTD." on Justia Law

The Estate of Frances Elaine Warren entered into a purchase and sale agreement with Tricore Investments, LLC involving real property near Priest Lake in Bonner County, Idaho. Before closing, the Estate sold the property to other buyers: John Stockton and Todd Brinkmeyer. Tricore filed a complaint against the Estate for breach of contract and violation of the Idaho Consumer Protection Act (“ICPA”), among other things, and sought specific performance of the purchase and sale agreement. The complaint also alleged that Stockton and Brinkmeyer tortiously interfered with the purchase and sale agreement and that the Estate, Stockton, and Brinkmeyer (collectively, “Appellants”) engaged in a civil conspiracy. The case proceeded to a bench trial where the district court found: (1) the purchase and sale agreement between the Estate and Tricore constituted a valid and enforceable contract; (2) the Estate breached the contract when it sold the property to Stockton and Brinkmeyer; (3) the Estate’s actions violated the ICPA; (4) Stockton and Brinkmeyer tortiously interfered with the contract; and (5) Appellants engaged in a civil conspiracy. The district court ordered specific performance of the contract but declined to award any additional damages. The Estate and Stockton jointly appealed; Brinkmeyer appealed separately. The Estate argued the purchase and sale agreement was not a valid, enforceable contract because it violated the statute of frauds and there was no meeting of the minds. In the alternative, the Estate argued it did not breach the contract because Tricore repudiated it, and it did not violate the ICPA. Stockton and Brinkmeyer argued they did not tortiously interfere with the purchase and sale agreement. Together, Appellants argued they did not engage in a civil conspiracy. The Idaho Supreme Court affirmed the district court’s grant of summary judgment for Tricore on the Estate’s statute of frauds defense. The Court also affirmed the district court's findings that: (1) the Estate breached the Tricore PSA; (2) the Estate violated the ICPA; and (3) Stockton and Brinkmeyer tortiously interfered with the Tricore PSA. The district court's finding that Appellants engaged in a civil conspiracy was reversed. As a result, the attorney fee award was affirmed only as it applied to the Estate from fees against Stockton and Brinkmeyer. Tricore was not entitled to monetary damages on the tortious interference claim. View "Tricore Investments LLC v. Estate of Warren" on Justia Law

Cases consolidated for review by the Idaho Supreme Court were appeals of three separate judgments ejecting three non-beneficiary parties from the property of an estate. The personal representative of the Estate of Victoria H. Smith (“the Estate”) brought three separate ejectment actions against the Law Office of Vernon K. Smith, LLC, and Vernon K. Smith Law, PC (collectively “VK Law”); David R. Gibson; and Vernon K. Smith, III (“Vernon III”), after each party refused his demands to vacate their respectively occupied properties. None of the parties were beneficiaries of the Estate. The district courts granted partial judgment on the pleadings in favor of the personal representative in all three actions, entering separate judgments ejecting Gibson, Vernon III, and VK Law from the Estate’s properties. On appeal, Appellants raised numerous issues relating to the personal representative’s authority to eject them from the properties. Ford Elsaesser, the personal representative of the Estate, argued on appeal that the district courts did not err in granting partial judgment on the pleadings because he had sufficient power over Estate property to bring an ejectment action on the Estate’s behalf. Finding no reversible error, the Supreme Court affirmed the district court. View "Elsaesser v. Gibson" on Justia Law

In 2013, Tech Landing, LLC leased a building to JLH Ventures, LLC (“JLH”) to operate a paintball business. After the building burned down in 2017, Tech Landing sued JLH, alleging breach of contract, breach of the covenant of good faith and fair dealing, and negligence. The breach of contract and breach of the covenant of good faith and fair dealing claims involved payment of rent after the building was destroyed and the failure to insure the building against fire loss. Those claims were dismissed by stipulation of the parties and were not at issue here. With respect to its negligence claim, Tech Landing alleged the fire was caused by the negligence of JLH. After ruling certain opinions of Tech Landing’s expert witnesses were inadmissible, the district court granted summary judgment to JLH. After review, the Idaho Supreme Court affirmed the district court’s ruling on the admissibility of the expert opinions, but reversed its grant of summary judgment because there were genuine issues of material fact that had to be decided by a jury. View "Tech Landing LLC v. JLH Ventures LLC" on Justia Law

In this case, the Idaho Supreme Court was asked to revisit its decision in Idaho v. Clarke, 446 P.3d 451 (2019), and determine whether its holding was applicable in an administrative proceeding regarding the suspension of driving privileges based on an alleged case of driving under the influence (“DUI”). The Idaho Transportation Department (“ITD”) appealed a district court’s decision overturning its one-year suspension of Jasmine Reagan’s driving privileges. ITD based the administrative license suspension (“ALS”) on Reagan’s arrest for misdemeanor driving under the influence of alcohol and the results of subsequent testing of her blood alcohol content (“BAC”). The arresting officer, acting on a citizen’s report of a possible intoxicated driver, did not personally witness Reagan operating or in control of a vehicle. Reagan failed field sobriety tests administered at her home and, after being arrested, failed a breathalyzer test. Reagan received notice that her driver’s license was suspended for one year, which she appealed. An administrative hearing officer for ITD, relying on Idaho Code section 49-1405, upheld the license suspension. However, on appeal the district court overturned the suspension pursuant to Clarke, reasoning that because the misdemeanor DUI was completed outside the officer’s presence, the arrest required a warrant. On certiorari review, the issues presented were: (1) whether the breathalyzer test was administered pursuant to a lawful arrest; and (2) if the arrest was unlawful, whether test results obtained pursuant to an unlawful arrest are admissible in an ALS hearing before the ITD. The SupremeCourt concluded Idaho Code section 49-1405, as applied in this case, violated the Idaho Constitution. Accordingly, the Court affirmed the district court's decision to overturn ITD's suspension of Reagan's license. View "Reagan v. Idaho Transportation Department" on Justia Law