Justia Idaho Supreme Court Opinion Summaries

The grant of summary judgment dismissed an action originally brought by Diane Brooks against Wal-Mart Stores, Inc., (“Wal-Mart”) based on injuries Brooks received when she slipped and fell on a puddle of water near a Rug Doctor self-service kiosk (the “kiosk”) inside a store in Boise, Idaho. Brooks based her claims on premises liability and negligent mode of operation, alleging Wal-Mart knew or should have known that water could spill or leak onto the floor near the kiosk. Wal-Mart moved for summary judgment, arguing that Brooks failed to establish Wal-Mart had actual or constructive notice of the condition that caused her injury, because there was no evidence showing where the liquid came from, how long it had been on the floor, or what it was. The district court agreed; the Supreme Court did not. The Supreme Court found material issues of fact existed, thus precluding summary judgment. The case was reversed and remanded for further proceedings. View "Brooks v. Wal-Mart" on Justia Law

The Idaho Supreme Court reversed the magistrate court in an expedited appeal regarding the termination of John Doe (2017-32)'s parental rights. John Doe is the father of minor children KB and AB (the “Children”). The Children entered the Idaho Department of Health and Welfare’s (“IDHW”) custody in December 2014 after the Twin Falls Police declared them to be in imminent danger. The Children were in their mother’s (“Mother”) care when the police arrested her for possession of a controlled substance. Law enforcement described the condition of Mother’s home at this time as “filthy, cluttered, and containing numerous safety hazards, including raw sewage being present in the basement.” An Idaho Department of Health and Welfare (IDHW) case plan, filed January 2015, included number of enumerated tasks for both Doe and Mother to complete in order for them to reunite with the Children. The case plan sought to provide Doe and Mother a framework to address “stable housing, sanitary living conditions, the need to obtain controlled substance abuse treatment, to remain clean/sober, and [to] stay out of jail.” Mother relapsed within weeks of a December 2016 order and was arrested for felony possession, kicked out of Drug Court, and went to prison. IDHW sought to terminate Doe and Mother’s parental rights. Doe had not completed his required drug treatment regimen by a first trial, he became more actively involved in his treatment plan by the time of a second trial. Doe showed other encouraging signs between the first and second trial as well, including significant progress on his case plan. However, the magistrate court noted that, despite progress, Doe still had not completed his case plan nor reunified with his children in the intervening period between the first and second trial. The court issued a Memorandum Decision granting termination of Doe and Mother’s parental rights on October 2, 2017, and entered a corresponding judgment ten days later on October 12, 2017. Mother did not appeal, but Doe timely filed his notice of appeal. The Supreme Court found the magistrate court’s December 2016 order stating that termination was not in the Children’s best interest was irreconcilable with IDHW’s first official recommendation following that order that termination “remains” in the Children’s best interest. The magistrate court’s October 2017 decision following the second trial highlighted Doe’s failure to reunify with the Children as a substantial factor in his ultimate decision to terminate. The magistrate court’s procedural error in not entering judgment for Doe and dismissing the petition upon finding that termination was not in the Children’s best interest affected Doe’s fundamental rights in this case. View "Dept. of Health & Welfare v. John Doe (2017-32)" on Justia Law

This case centers on efforts to collect payment for medical services. Medical Recovery Services, LLC (“MRS”), appealed a district court decision affirming rulings of the magistrate court in favor of the patient, Jared Neumeier. Neumeier’s doctor’s billing agent assigned the delinquent account to MRS for collection. Neumeier did not receive any attempted communications from his doctor’s office or MRS, nor did he receive any other form of demand for payment related to the delinquent account. Neumeier saw his doctor for other unrelated medical services, which resulted in a separate bills that were submitted to insurance for payment. MRS eventually sent a letter addressed to Neumeier at his correct address. The one-page letter was attached to MRS’s complaint and was the only communication to Neumeier from either his doctor or MRS. The letter listed Neumeier’s contact information, the amount owed (exclusive of interest), the name of the creditor (MRS), and paraphrased recitations of the required inclusions under the Fair Debt Collections Act. The undated notice letter did not identify the doctor or connect the debt with a particular bill or treatment. Without a response from Neumeier, MRS requested its legal counsel to file an action to recover the debt. Neumeier visited his doctor under the belief that the notice letter was a fraud or scam. During this visit, the office discovered that it had never submitted the bill to Neumeier’s insurer; however, the office also informed Neumeier that the account had already been assigned to MRS for collection. On the same date, MRS filed a complaint against Neumeier, seeking a total award of $1,891.37, including $958.63 for the principal amount, $282.39 in statutory prejudgment interest, and attorney’s fees and costs. The next day, Neumeier contacted MRS and was informed that he was “too late.” Neumeier was subsequently served with a complaint and summons. The bill subject to the collection action was eventually submitted to insurance, and all but a $42 co-payment was paid. The doctor’s office waived the co-payment. Once the account was satisfied, MRS refused to drop its suit, claiming it was still owed pre-judgment interest. A magistrate found MRS was not owed interest, and dismissed the case. The Idaho Supreme Court found no error in that judgment, and affirmed the magistrate’s decisions. View "Medical Recovery Svc v. Neumeier" on Justia Law

This case centers on efforts to collect payment for medical services. Medical Recovery Services, LLC (“MRS”), appealed a district court decision affirming rulings of the magistrate court in favor of the patient, Jared Neumeier. Neumeier’s doctor’s billing agent assigned the delinquent account to MRS for collection. Neumeier did not receive any attempted communications from his doctor’s office or MRS, nor did he receive any other form of demand for payment related to the delinquent account. Neumeier saw his doctor for other unrelated medical services, which resulted in a separate bills that were submitted to insurance for payment. MRS eventually sent a letter addressed to Neumeier at his correct address. The one-page letter was attached to MRS’s complaint and was the only communication to Neumeier from either his doctor or MRS. The letter listed Neumeier’s contact information, the amount owed (exclusive of interest), the name of the creditor (MRS), and paraphrased recitations of the required inclusions under the Fair Debt Collections Act. The undated notice letter did not identify the doctor or connect the debt with a particular bill or treatment. Without a response from Neumeier, MRS requested its legal counsel to file an action to recover the debt. Neumeier visited his doctor under the belief that the notice letter was a fraud or scam. During this visit, the office discovered that it had never submitted the bill to Neumeier’s insurer; however, the office also informed Neumeier that the account had already been assigned to MRS for collection. On the same date, MRS filed a complaint against Neumeier, seeking a total award of $1,891.37, including $958.63 for the principal amount, $282.39 in statutory prejudgment interest, and attorney’s fees and costs. The next day, Neumeier contacted MRS and was informed that he was “too late.” Neumeier was subsequently served with a complaint and summons. The bill subject to the collection action was eventually submitted to insurance, and all but a $42 co-payment was paid. The doctor’s office waived the co-payment. Once the account was satisfied, MRS refused to drop its suit, claiming it was still owed pre-judgment interest. A magistrate found MRS was not owed interest, and dismissed the case. The Idaho Supreme Court found no error in that judgment, and affirmed the magistrate’s decisions. View "Medical Recovery Svc v. Neumeier" on Justia Law

The district court granted summary judgment in favor of Marian Baker, Trustee of the Marian B. Baker Trust (“Baker”), for an easement over a logging road (“Alexanna Lane”) that crossed the property of KAL, LLC (“KAL”). Initially there were claims involving John and Vickie Stadler (the “Stadlers”), and Jose Melendreras and Jacqueline Diaz-Melendreras (the “Melendrerases”). However, the appeal here involved only the claims between Baker and KAL. In February of 2015 Baker filed a complaint to quiet title against KAL, the Stadlers and the Melendrerases to extinguish an easement on the Baker Property. The Stadlers answered Baker’s complaint and asserted claims against Baker and the Melendrerases to quiet title and for common law trespass. The Stadlers noted that access to the Baker Property was intended to run through the Melendreras Property, not through the KAL Property or the Stadler Property. Baker filed a motion for summary judgment with respect to Count I and Count II of the Stadlers’ counterclaim, asserting that she was entitled to use Alexanna Lane to access her property because: (1) a statutory easement was created pursuant to Idaho Code section 55-603; (2) the 1999 deed intended to create and describe the easement; (3) an implied easement existed; (4) an easement by necessity existed because there was no other access to a public road; and (5) there was an easement by prescription. The Stadlers opposed Baker’s motion for summary judgment, asserting that there was no easement created that allowed Baker to access Alexanna Lane. Amidst these disputes KAL filed an answer and counterclaim to Baker’s complaint, asserting that Baker had no legal right to travel across the KAL Property; KAL maintained the 1999 deed was ambiguous, and the language did not reserve an easement that ultimately Baker claimed she held. Finding no reversible error in the district court’s determination of the meaning of the easement language in the deed, the Idaho Supreme Court affirmed the district court’s judgment. View "Baker v. KAL, LLC" on Justia Law

The district court granted summary judgment in favor of Marian Baker, Trustee of the Marian B. Baker Trust (“Baker”), for an easement over a logging road (“Alexanna Lane”) that crossed the property of KAL, LLC (“KAL”). Initially there were claims involving John and Vickie Stadler (the “Stadlers”), and Jose Melendreras and Jacqueline Diaz-Melendreras (the “Melendrerases”). However, the appeal here involved only the claims between Baker and KAL. In February of 2015 Baker filed a complaint to quiet title against KAL, the Stadlers and the Melendrerases to extinguish an easement on the Baker Property. The Stadlers answered Baker’s complaint and asserted claims against Baker and the Melendrerases to quiet title and for common law trespass. The Stadlers noted that access to the Baker Property was intended to run through the Melendreras Property, not through the KAL Property or the Stadler Property. Baker filed a motion for summary judgment with respect to Count I and Count II of the Stadlers’ counterclaim, asserting that she was entitled to use Alexanna Lane to access her property because: (1) a statutory easement was created pursuant to Idaho Code section 55-603; (2) the 1999 deed intended to create and describe the easement; (3) an implied easement existed; (4) an easement by necessity existed because there was no other access to a public road; and (5) there was an easement by prescription. The Stadlers opposed Baker’s motion for summary judgment, asserting that there was no easement created that allowed Baker to access Alexanna Lane. Amidst these disputes KAL filed an answer and counterclaim to Baker’s complaint, asserting that Baker had no legal right to travel across the KAL Property; KAL maintained the 1999 deed was ambiguous, and the language did not reserve an easement that ultimately Baker claimed she held. Finding no reversible error in the district court’s determination of the meaning of the easement language in the deed, the Idaho Supreme Court affirmed the district court’s judgment. View "Baker v. KAL, LLC" on Justia Law

This case addressed whether the issuance of a tax deed extinguished a prescriptive easement across a parcel of land by operation of former Idaho Code section 63-1009. The Owens purchased a small parcel of land (“the Orphan Parcel”) from Kootenai County after a tax sale. A dispute arose as to whether the Regans had the right to drive across the Orphan Parcel. The Regans sued the Owens to reform the tax deed to include an express easement and to establish a prescriptive easement. The district court granted summary judgment in favor of the Regans, ruling that the Owens’ deed contained a mutual mistake and should be reformed to reflect an express easement that the original grantors intended. The Owens appealed and the Idaho Supreme Court held that the deed should not be reformed. The Court also vacated a portion of the district court’s judgment and remanded the case for further proceedings. On remand, the district court granted summary judgment in favor of the Owens, finding that any prescriptive easement was extinguished by Idaho Code section 63-1009, which provided that tax deeds conveyed property free of all “encumbrances.” The Regans appealed; shortly thereafter, the Idaho Legislature amended Idaho Code section 63-1009. In September 2017, the Idaho Supreme Court released its original decision in this appeal, then granted the Regans’ petition for rehearing. After review, the Supreme Court vacated the judgment entered in favor of the Owens and remanded this case for further proceedings. View "Regan v. Owen" on Justia Law

Medical Recovery Services, LLC (“MRS”) appealed a district court’s judgment denying its request for postjudgment attorney fees on an appeal. The dispute arose after MRS attempted to collect a debt owed by Robert Lopez. The magistrate court entered a default judgment and awarded attorney fees to MRS. MRS continued to incur attorney fees while attempting to collect on the default judgment and filed a request to recover its postjudgment attorney fees, which the magistrate court denied. MRS appealed, and the district court reversed the magistrate court’s denial of postjudgment attorney fees, but declined to award MRS attorney fees related to its appeal of the magistrate court’s decision. Essentially, MRS was attempting to collect fees for attempting to collect attorney fees, not for attempting to collect on the judgment. The Idaho Supreme Court determined Idaho law did not support such attempts, and affirmed the district court’s denial of MRS’ requests. View "Medical Recovery Svcs. v. Lopez" on Justia Law

Gregory Hull appealed a district court decision concerning the allocation of development costs he was required to share with Richard Giesler and Idaho Trust Deeds, LLC. This case was the second appeal arising from a series of oral and written agreements between the parties to exchange and subdivide property. Hull argued the district court erred by excluding testimony from his expert witness. Both parties requested an award of attorney fees on appeal. Finding no abuse of discretion in the district court’s decision to disallow the expert’s testimony, the Idaho Supreme Court affirmed. View "Hull v. Geisler" on Justia Law

Justin Vigos appealed a district court’s decision to reverse a magistrate court’s order granting his motion for summary judgment against MFG Financial, Inc. (MFG). MFG initiated this action to recover damages from a breach of contract. In 2007, Vigos purchased a vehicle from Karl Malone Toyota. The contract was assigned to Courtesy Auto Credit (Courtesy). After some time, Vigos defaulted on the contract and the vehicle was repossessed and sold at auction. Courtesy then allegedly assigned the contract to MFG who initiated this action in 2015. After discovery, the parties each filed a motion for summary judgment. The magistrate court granted Vigos’s motion for summary judgment, finding that MFG had not presented sufficient admissible evidence to show that it was a real party in interest. MFG appealed and the district court reversed the decision of the magistrate court. Vigos appealed, arguing that the district court applied the wrong standard when it failed to first determine if evidence was admissible before considering it for purposes of summary judgment. MFG cross appealed, arguing that the district court erred when it failed to award it attorney fees on appeal. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed. View "MFG Financial Inc. v. Vigos" on Justia Law