Justia Idaho Supreme Court Opinion Summaries

In 2010, Kermit Jackson filed a complaint against Jennifer Crow arising from a 2008 automobile collision. No substantive action took place in the trial court until 2016 when Crow moved for summary judgment. In the interim, Crow filed for bankruptcy in 2014 listing Jackson as a potential unsecured creditor with a claim of unknown value. Jackson filed a proof of claim with the bankruptcy court and eventually received his pro rata share of the distribution of Crow’s assets. Crow received a bankruptcy discharge in 2014, releasing her from personal liability on the claim. Afterwards, Jackson proposed to move forward with this case against Crow as a nominal defendant, seeking to secure a judgment in order to recover from Crow’s insurer, rather than Crow personally. Crow’s motion for summary judgment argued that: (1) allowing Jackson’s case to go forward against her violated the permanent discharge injunction of 11 U.S.C. secs. 524 and 727; (2) even if this procedure did not violate the Bankruptcy Code’s permanent injunction, naming her as a nominal defendant was (a) not permitted by Idaho case law, the Idaho Rules of Civil Procedure, and Idaho’s no-direct-action rule, and (b) violated the Bankruptcy Code’s policy of providing her a financial “fresh start.” In a case of first impression, the district court ruled in favor of Crow, reasoning that allowing the case to proceed against Crow would violate 11 U.S.C. 524 by impermissibly causing negative economic consequences for Crow. The district court further reasoned that allowing Jackson to proceed directly against Crow’s insurer would violate the no-direct-action rule and permitting Jackson to proceed against Crow nominally was not permitted by the Idaho Rules of Civil Procedure or this Court’s precedent. The Idaho Supreme Court concluded the district court erred in granting Crow summary judgment: the district court misapplied the no-direct-action rule in this case. The judgment was vacated and the matter remanded for further proceedings. View "Jackson v. Crow" on Justia Law

At issue in this appeal was the administrative order entered by Administrative District Judge Melissa Moody for the Fourth District declaring appellant, Mark Colafranceschi, a vexatious litigant pursuant to Idaho Court Administrative Rule 59. Colafranceschi and his former wife, Julie Neustadt had been involved in contentious litigation dating back to May 2016. The administrative district judge determined that Colafranceschi had satisfied I.C.A.R. 59(d)(1) because in the preceding seven years he had represented himself in at least three cases that were finally determined adversely to him, and he repeatedly relitigated outcomes in two cases, and propounded discovery requests for improper purposes. Colafranceschi appealed the order, arguing that the administrative judge erred in declaring him a vexatious litigant. The Idaho Supreme Court affirmed the administrative district judge’s order finding Colafranceschi a vexatious litigant and upheld the order prohibiting Colafranceschi from filing any new pro se litigation in the courts of this state without first obtaining leave of a presiding judge. View "Colafranceschi v. Moody" on Justia Law

Burns Concrete, Inc., and Canyon Cove Development Company, LLP, (Canyon Cove), appealed a district court judgment in favor of Nora Mulberry and TN Properties, LLC, (collectively, Mulberry) regarding the extinguishment of a right of first refusal (ROFR). In 1999, Nora and Theodore Mulberry sold a piece of real property to Canyon Cove and included a ROFR to a nearby, distinct parcel of real property (ROFR Property). Twelve days later, Canyon Cove conveyed its interest in both the purchased property and the ROFR to Burns Concrete and recorded the deed to the purchased property with the Bonneville County, Idaho Recorder. In 2005, Nora Mulberry and her husband (now deceased) conveyed the ROFR Property to their wholly owned limited liability company, TN Properties, and subsequently recorded the deed with the Bonneville County Recorder. In 2016, Mulberry filed a complaint seeking declaratory judgment and subsequently a motion for partial summary judgment. The district court entered partial summary judgment in favor of Mulberry finding the ROFR was personal to Mulberry and Canyon Cove, and it was subsequently extinguished when Canyon Cove assigned it to Burns Concrete. On reconsideration, the district court held that the ROFR was a servitude appurtenant to the purchased property, and reaffirmed it was extinguished by Canyon Cove’s conveyance to Burns Concrete. Burns Concrete and Canyon Cove timely appealed. The Idaho Supreme Court reversed and remanded, finding: (1) the ROFR was personal to the parties, and thus, non-assignable; and (2) the ROFR was not extinguished when Canyon Cove purported to assign it to Burns Concrete. Therefore, the district court erred in ruling the ROFR was extinguished after Canyon Cove purported to assign it to Burns Concrete; the matter was remanded for a determination of the other issues raised in the complaint that were previously dismissed as moot. View "Mulberry v. Burns Concrete" on Justia Law

In December 2016, the J.R. Simplot Company (Simplot) filed suit in Washington state relating to the dissolution of a business relationship between Simplot and two entities Simplot co-owned with Frank Tiegs (Tiegs). Dickinson Frozen Foods (DFF), also operated by Tiegs, was not named as a party in the Washington litigation; however, the complaint contained allegedly defamatory statements about DFF. In March 2017, DFF filed suit in Idaho district court alleging defamation per se against Simplot and its Food Group President Mark McKellar (McKellar), as well as the two law firms who represented Simplot in the Washington litigation: Yarmuth Wilsdon, PLLC (Yarmuth) and Thompson Coburn, LLP (Thompson). DFF also claimed breach of contract against Simplot, claiming Simplot had breached a non-disclosure agreement (NDA). Counsel for Yarmuth and Thompson made special appearances so that they could contest personal jurisdiction, and simultaneously moved for dismissal on that basis. Yarmuth, Thompson, McKellar, and Simplot also sought dismissal or partial summary judgment on the basis of the litigation privilege. The district court dismissed DFF’s claims for defamation per se against all defendants, determining the statements were protected by the litigation privilege. However, the district court declined to rule on Yarmuth and Thompson’s motions to dismiss for lack of jurisdiction in light of its rulings on the merits. Later, the district court granted Simplot’s motion for summary judgment on DFF’s breach of contract claim. DFF appealed. The Idaho Supreme Court determined it lacked personal jurisdiction over Yarmuth and Thompson; the Court affirmed the district court in all other respects. View "Dickinson Foods v. J.R.Simplot" on Justia Law

The City of Middleton (the City) appealed the district court’s grant of summary judgment to Martin and Patricia Galvin on their claim of prescriptive easement and its award of attorney fees to the Galvins pursuant to Idaho Code section 12-117. In 2016, the Galvins filed a complaint against the City of Middleton for quiet title, declaratory judgment, and a permanent injunction concerning their use of Willis Road, a private road that the City acquired in 2015. The Galvins alleged that their use of Willis Road since 1949 created a prescriptive easement entitling them to use the road for ingress, egress, and farming and irrigation purposes. The City’s answer denied the existence of the easement but did not dispute that the Galvins had used the road for the past sixty years. Finding no reversible error in the grant of summary judgment, the Idaho Supreme Court affirmed. View "Galvin v. City of Middleton" on Justia Law

Appellants Ryan and Kathryn McFarland owned real property in Garden Valley, Idaho, which feathred three structures insured through Liberty Mutual Insurance Group: a main cabin; a detached garage with an upstairs “bonus room”; and a pump house containing a geothermal well. The policy provided two types of coverage for structures. Coverage A (“Dwelling Coverage”) provided up to $188,500 in coverage for “the dwelling on the ‘residence premises’. . . including structures attached to the dwelling . . .” and Coverage B (“Other Structures Coverage”) provided up to $22,350 for “other structures on the ‘residence premises’ set apart from the dwelling by clear space.” In February 2017, a radiant heater burst in the bonus room and damaged the garage and its contents. After the McFarlands filed a claim, Liberty stated that the damage was covered under the policy. Believing the damage to fall under the Dwelling Coverage, the McFarlands hired contractors to repair the damage. However, after Liberty paid out a total of $23,467.50 in March 2017, Liberty stated that the coverage was exhausted because the damage fell under the Other Structures Coverage. This led the McFarlands to sue, alleging among other claims, breach of contract based on Liberty’s interpretation of the policy. The parties filed cross motions for summary judgment on the issue of whether the damage fell under the Dwelling Coverage or the Other Structures Coverage. Ruling that the policy unambiguously provided coverage for the garage under the Other Structures Coverage, the district court denied the McFarlands’ motion and granted Liberty’s. The McFarlands appealed. Finding that the policy at issue here failed to define the term "dwelling", and the term was reasonably subject to differing interpretations, the Idaho Supreme Court reversed the award of summary judgment and remanded for further proceedings. View "McFarland v. Liberty Insurance Corp" on Justia Law

Vernon K. Smith (Smith) appealed a district court’s award of sanctions. This case originally arose from a contract for the sale of lima beans between Victoria Smith (“Victoria”) and Treasure Valley Seed Company (“TVSC”). As Victoria’s son, Smith filed a complaint against TVSC for breach of contract. The original complaint named Victoria as plaintiff, by and through her attorney in fact, Vernon K. Smith, by and through his “Durable and Irrevocable Power of Attorney.” TVSC learned that Victoria had died three months before Smith’s filing of the complaint. Based on Victoria’s death, TVSC moved to dismiss the complaint, arguing that there was no longer a real party in interest. Smith argued that he was a real party in interest because the power of attorney he drafted was irrevocable. The district court held that Smith’s power of attorney terminated on Victoria’s death and granted TVSC’s motion to dismiss. At the hearing for costs and fees, the district court stated that Victoria’s estate should have brought the action, but because no probate had been filed, there was no real party in interest able to substitute or join. After ruling that the complaint was unreasonable and without foundation, the district court awarded attorney fees to TVSC under Idaho Code section 12-121, to be assessed jointly and severally against Victoria and Smith, as counsel. Smith appealed both the dismissal of the case and the award of attorney fees, but his appeal of the dismissal was not filed timely, so the Idaho Supreme Court only addressed Smith’s appeal of the attorney fees. The Idaho Supreme Court concurred with the district court with respect to termination of the power of attorney. Smith maintained the power of attorney gave him authority to sue on his mother's behalf, and upon remand of the case to the district court to determine the appropriate amount of fees to be assessed, the trial court awarded fees as a sanction under Rule of Civil Procedure 11. The Supreme Court declined of offer Smith "an opportunity for a mulligan" on his arguments about the power of attorney, and found the district court did not abuse its discretion when it awarded attorney fees, or levied sanctions against Smith. View "Smith v. Treasure Valley Seed Co." on Justia Law

This case began as a highly contentious divorce proceeding between vexatious litigant-appellant Ronald Van Hook and his then-wife Dawn Cannon, in which Van Hook lost custody of his children (hereinafter the Canyon County divorce case). Van Hook was represented by legal counsel only for portions of the divorce proceeding as each of his attorneys withdrew from the case. Following each attorney’s departure, Van Hook filed a new series of pro se motions and objections to the court, which were similar and repetitive. Van Hook filed numerous motions to amend the magistrate court’s temporary custody and visitation orders, disqualify the magistrate judge assigned to the case, change venue, and find Cannon in criminal contempt. He also filed multiple petitions for a writ of habeas corpus. His pro se motions and petitions were continuously denied and largely found to be frivolous. When Van Hook appealed the Canyon County divorce case, the district court found Van Hook’s motion to recuse the magistrate judge frivolous, and that his appeal was also without foundation. The issue this case presented for the Idaho Supreme Court's review arose from an administrative order declaring Van Hook a vexatious litigant under Idaho Court Administrative Rule 59. The Idaho Supreme Court determined Van Hook: met I.C.A.R. 59 (d)(1) because he commenced more than three pro se litigations that were adversely determined against him; met I.C.A.R. 59 (d)(2) because he repeatedly attempted to relitigate the final divorce and custody determinations by the magistrate court; and met I.C.A.R. 59 (d)(3) because he repeatedly filed frivolous motions and pleadings. Therefore, the Supreme Court affirmed the prefiling order declaring Van Hook a vexatious litigant. View "Order Re: Vexatious Litigant (Van Hook)" on Justia Law

This appeal arose out of an Ada County Board of Commissioners’ decision to direct issuance of a tax deed. The property owner, James Floyd, was incarcerated in the county jail throughout the proceedings, and alleged he never received official notice of the pending tax deed until a month before his hearing. Despite having his jail address on file, the County Treasurer delivered statutory notices to Floyd’s vacant home. However, she also sent Floyd letters at the jail apprising him of the tax deed proceedings and delinquent taxes owed. The Board of Commissioners determined that Floyd received sufficient due process, and directed the tax deed to issue. The district court affirmed, holding that Floyd had actual notice despite the Treasurer’s failure to comply with statutory notice requirements. The Idaho Supreme Court affirmed the district court’s determination because it found Floyd had actual notice of the pending tax deed. View "Floyd v. Bd of Ada County Commissioners" on Justia Law

Monitor Finance, L.C., and First Capital Funding, L.C., (collectively referred to as the Beneficiaries) were the holders of a deed of trust, which encumbered the real property claimed to be owned in fee simple by Wildlife Ridge Estates, LLC (Wildlife LLC). Prior to this judicial foreclosure action being brought, Wildlife LLC filed suit against the Beneficiaries seeking to quiet title to the real property. In that previous action, Wildlife LLC alleged that the Beneficiaries no longer retained an interest in the property because the debt underlying the promissory note had been paid in full. By stipulation of the parties, that quiet title action was ultimately dismissed with prejudice. Subsequently, the Beneficiaries initiated this action to foreclose the deed of trust based on their contention that the debt created by the promissory note had not been paid and was in default. The Beneficiaries moved the district court for summary judgment, contending that Wildlife LLC’s affirmative defenses and counterclaim were barred by res judicata because the previous quiet title action brought by Wildlife LLC had been dismissed on its merits. The district judge granted the Beneficiaries’ motion and denied Wildlife LLC’s motion to reconsider. In doing so, the district court summarily dismissed Wildlife LLC’s counterclaim and affirmative defenses. The district court ultimately entered summary judgment in favor of the Beneficiaries. Wildlife LLC appealed, claiming, among other things, that the district court misapplied the doctrine of res judicata. The Idaho Supreme Court diagreed, finding Wildlife LLC's affirmative defenses and counterclaim were correctly barred by res judicata. View "Monitor Finance v. Wildlife Ridge Estates" on Justia Law