Justia Idaho Supreme Court Opinion Summaries

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

An employee brought claims under provisions of the Idaho Human Rights Act, claiming: (1) the employer unlawfully discriminated against him based on race. He also alleged (2) breach of employment contract and the implied covenant of good faith. Furthermore, the employee (3) sought to disqualify the trial judge for cause based upon perceived bias. The district court denied the employee’s disqualification motion and granted summary judgment for the employer on all of the employee’s claims. Finding no reversible error, the Idaho Supreme Court affirmed judgment entered in favor of the employer. View "Mendez v. University Health Svcs BSU" on Justia Law

The Idaho Supreme Court answered a certified question of Idaho law from the United States District Court for the District of Idaho. The question certified centered on whether, for purposes of the dispute in this lawsuit, the terms ‘state board of correction’ as used in Idaho Code 20-237B(1) and ‘department of correction’ as used in Idaho Code § 20-237B(2), included privatized correctional medical providers under contract with the Idaho Department of Correction. The Court answered the question certified in the negative. View "In Re: Pocatello Hospital, LLC v. Corazon, LLC" on Justia Law

Chad and Jane Barnes appealed a district court’s order granting summary judgment and dismissing their lawsuit against Kirk Jackson. In 2014, Barnes filed suit against Jackson seeking a declaration of forfeiture as to Jackson’s water right (“Jackson’s Right”). Barnes alleged that Jackson’s Right was unused for the five-year statutory period and was therefore forfeited. The district court explained that, under the resumption-of-use doctrine, statutory forfeiture is not effective if, after five years of nonuse, an appropriator resumes use prior to the assertion of a claim of right by a junior appropriator. The district court noted that Jackson had used the water as early as 2012, two years before Barnes purchased his property; therefore, Barnes was barred from asserting that he had relied upon Jackson’s unused water since 2012. The district court acknowledged Barnes’ related argument, that he was somehow connected to his predecessor in interest, and therefore could assert the predecessor’s claim of right. However, the district court noted that there was no statutory or legal basis for the position. The district court granted summary judgment in favor of Jackson. Finding no reversible error after review of the district court record, the Idaho Supreme Court affirmed. View "Barnes v. Jackson" on Justia Law

This is an appeal from the district court’s grant of summary judgment against Dea Haight (“Haight”) and the dismissal of her complaint for damages and declaratory and injunctive relief. Haight alleged that the Idaho Department of Transportation (“ITD”) was negligent in placing and maintaining construction barrels on Interstate 90 (“I-90”) in Shoshone County, Idaho. At Mile Post 53, Haight alleges that one of the barrels was completely within the lane of travel in the north passing lane for eastbound traffic - the only lane open for eastbound traffic at the time. Haight claims the barrel caught both arms on the awning of her fifth wheel camper trailer, ripping one arm completely away from the body of the camper and partially tearing away the other arm. In addition to her negligence claim, Haight alleged portions of Idaho’s motorcycle and driver’s manuals published by the State misrepresent the law and prescribe standards which present a danger to motorists. The district court concluded that Haight failed to present sufficient evidence to support her negligence claim and that she lacked standing to bring a declaratory judgment action against ITD. Haight argued on appeal the trial court erred. The Idaho Supreme Court affirmed the trial court’s dismissal of Haight’s case. View "Haight v. Idaho Dept of Transportation" on Justia Law

Appellant Jadwiga Melton (“Jadwiga”), challenged a district court’s determination that Respondent Heinz Alt (“Heinz”), filed a timely claim against the Estate of Robert Ernest Melton (“Robert”) and Hedwig Melton (“Hedy”). Hedy died in 2008, and in 2010 Robert married Jadwiga. In 2013, Robert died. Jadwiga commenced joint probate proceedings for both Hedy and Robert, pursuant to Idaho Code section 15-3-111, because Hedy’s will was never probated. Heinz filed a creditor claim against the estate for approximately to the penny $102,574.50, alleging that he loaned money to Hedy and Robert to build a home and in exchange they agreed to execute wills that would leave their estate to him. Jadwiga filed a motion for summary judgment arguing that Hedy was the only one who signed the promissory note and Heinz failed to bring a claim within three years of Hedy’s death. The magistrate court determined that, because Heinz failed to bring the claim against Hedy’s estate within three years of her death, his claim was barred by Idaho Code section 15-3-803. Heinz appealed and the district court reversed the magistrate court, holding that Heinz’s claim was timely, pursuant to Idaho Code section 15-3-111, because Heinz brought his creditor claim within three years of Robert’s death. Upon review, the Idaho Supreme Court determined the district court erred when it construed the statutory language of 15-3-111 because the statute was not ambiguous. Accordingly, the Supreme Court reversed the district court and remanded the case for further proceedings. View "Melton v. Alt" on Justia Law

This water rights appeal stemmed from two consolidated subcases, litigated in the Snake River Basin Adjudication (SRBA). The subcases concerned the United States’ late claims (Late Claims) filed in January 2013, which asserted “supplemental beneficial use storage water rights” claims under the constitutional method of appropriation to store water in priority after flood-control releases. The special master recommended that the State’s motion for summary judgment be granted, concluding the Late Claims should be disallowed because, as the Director of the Idaho Department of Water Resources (Director) recommended, the Late Claims asserted rights that had not been claimed when the underlying water rights were adjudicated and decreed. Alternatively, the special master concluded the Late Claims should be disallowed because, as intervenor Black Canyon Irrigation District (BCID) asserted, the decreed water rights already authorized the rights the Late Claims were asserting, thus, unnecessary. The district court agreed with the special master insofar as the Late Claims were precluded. However, the district court rejected the special master’s alternative recommendation that the Late Claims were duplicative of the rights already decreed and unnecessary. The district court entered judgment reflecting these conclusions. BCID timely appeals and the Idaho Supreme Court affirm the district court’s conclusion the special master exceeded the district court’s orders of reference by making the “alternative basis” recommendation. View "Black Canyon Irrig Dist v. State / Suez Water" on Justia Law