Justia Idaho Supreme Court Opinion Summaries

This case arose from an employment agreement between Allen Nettleton and Canyon Outdoor Media, LLC (“Canyon Outdoor”). The parties disagreed with respect to Nettleton’s entitlement to commission wages following his resignation. The district court granted summary judgment in favor of Nettleton and denied Canyon Outdoor’s motion for summary judgment and motion for reconsideration of the rulings on summary judgment. Canyon Outdoor argued the district court erred in granting Nettleton’s motion for summary judgment: (1) because the parties did not agree to a term in the employment agreement that covers post-separation compensation; (2) because the Snake River Dental contract did not establish a “course of dealing”; and (3) because Nettleton was required to service client accounts to be entitled to commission wages. Among these, the third argument was essentially a dispositive issue in the summary judgment rulings at the district court. For these reasons, Canyon Outdoor contended the district court improperly applied the relevant standard of review in reaching its conclusion that a servicing requirement did not exist under the employment agreement. The Idaho Supreme Court agreed with Canyon Outdoor and found the judgment in favor of Nettleton had to be vacated. View "Nettleton v. Canyon Outdoor Media" on Justia Law

Galust Berian filled in a ditch on property owned by Yvette Sturgis. The ditch served property owned by Jade and Kylie Mortensen. The Mortensens sued Berian and Sturgis seeking damages and to have the ditch reopened. Berian counterclaimed for trespass. The district court ruled in favor of the Mortensons on their claim regarding the ditch and awarded the Mortensens damages for the cost of repairing the ditch. The district court also found in favor of Berian on his counterclaim for trespass but awarded only nominal damages. Berian and Sturgis appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Mortensen v. Berian" on Justia Law

Appellants Ronald and Margaret Swafford challenged a district court’s grant of summary judgment in favor of Respondent Huntsman Springs, Inc. The action stemmed from the Swaffords’ claim that Huntsman Springs failed to comply with the Master Plan by essentially cutting off their property from the development. The district court granted summary judgment in favor of Huntsman Springs after concluding that all of the Swaffords’ claims were barred by the applicable statutes of limitations. It was uncontested that the improvements were completed in 2008. Without ruling upon whether Huntsman Springs misrepresented the development of the property at issue, the Idaho Supreme Court determined if Huntsman Springs misrepresented the development of the Property, the Swaffords could have discovered the misrepresentation when the improvements were completed in 2008. The Swaffords did not bring their misrepresentation action until July 17, 2015, which was nearly four years after the deadline. Finding no genuine issues of fact with respect to the time at which the Swaffords' causes of action accrued, the Supreme Court affirmed the district court's judgment. View "Swafford v. Huntsman Springs Inc" on Justia Law

Jane Doe and John Doe (2017-19) (“Mother,” “Father,” and collectively, “Parents”) appealed a magistrate court’s Final Judgment terminating their parental rights to Jane Doe II (“Child”). Jane Doe I and John Doe I (“Grandmother,” “Grandfather”) initiated the underlying action by filing a Petition for Termination of Parental Rights and a Petition for Adoption. The magistrate court issued a Final Judgment terminating Parents’ parental rights after concluding that Parents had abandoned Child and that the termination of Parents’ parental rights was in Child’s best interest. On appeal, Parents challenged the magistrate court’s conclusion that Child was abandoned and that termination of parental rights was in Child’s best interest. Finding no abuse of discretion or other reversible error, the Idaho Supreme Court affirmed the termination. View "John & Jane Doe (2017-19) v. John & Jane Doe I" on Justia Law

Appellant Norman Wechsler and Respondent Sharon Wechsler, divorced in New York in 2005. A Divorce Judgment was entered by the New York County Clerk on February 3, 2006, setting forth a distribution of the parties’ property and maintenance obligations. In 2014, Sharon moved a New York court for an order to direct the entry of a money judgment in her favor because Norman had defaulted on his obligation to transfer funds according to the Divorce Judgment. A New York court granted Sharon’s motion and issued a $9,468,008.98 Judgment in her favor. In 2012, Sharon partially collected on a $17,669,678.57 divorce-related Judgment by executing on Norman’s house in Colorado. Between the acquisition of Norman’s Colorado house, and the filing of the Foreign Judgment in Idaho, Norman did not disclose his updated address; accordingly, in an affidavit filed with the Idaho Foreign Judgment, Sharon indicated that Norman’s last known address was the Colorado house that she had acquired. Unbeknownst to Sharon, Norman had moved to a rental apartment in Angel Fire, New Mexico. After living in New Mexico for one year, Norman moved to Pocatello, Idaho. The New York Judgment at issue here was filed in Idaho as a “Foreign Judgment,” and the issues before the Idaho Supreme Court relate to Sharon’s attempts to collect. Norman challenged the Idaho district court’s order in favor of Sharon; he attacked the judgment on jurisdictional, constitutional, abuse-of-discretion and procedural grounds. Finding none of these arguments availing, the Idaho Supreme Court affirmed the Idaho district court’s judgment and awarded Sharon attorney fees. View "Wechsler v. Wechsler" on Justia Law

Philip Hudson appealed a district court’s grant of partial summary judgment in favor of the State of Idaho, the Idaho State Board of Land Commissioners and the Idaho Department of Lands (collectively, the “State”). The district court found that Hudson violated the Idaho Lake Protection Act (the “LPA”) when he placed fill in the bed of Priest Lake without a permit. Hudson disputed the location of the Ordinary High Water Mark (the “OHWM”) and argued the fill was placed on his own property to protect it from erosion. Hudson argued that there was an issue of material fact regarding the location of the OHWM, which made summary judgment improper. Finding the dispute regarding the OHWM was not a material fact in determining whether Hudson violated the LPA, the Idaho Supreme Court affirmed summary judgment. View "Idaho Board of Land v. Hudson" on Justia Law

Dennis Current appealed an Idaho Industrial Commission decision that determined he was ineligible for unemployment benefits based on willful underreporting of his earnings to the Idaho Department of Labor (“IDOL”). IDOL discovered wage discrepancies between the amount reported by Current and the amount reported by his employer, Wada Farms Partnership for two weeks in March 2016. On appeal, Current disputed that he “willfully” misrepresented his wages. Finding "substantial and competent evidence" supported the Commission's finding, the Idaho Supreme Court affirmed the Commission's decision. View "Current v. Dept of Labor" on Justia Law

This was an insurance bad faith case arising out of a claim for underinsured motorist coverage. In May 2008, Peggy Cedillo was injured in a collision while riding as a passenger on the back of a motorcycle. About a year after the collision, she settled her claim against the motorcycle driver for $105,000, the total amount available under his insurance policy. Cedillo married the motorcycle driver about eight months after the collision, and he was her lawyer in this lawsuit and designated as one of her experts. Cedillo claimed the district court erred when it: (1) granted summary judgment in favor of Farmers on her bad faith claim; (2) denied discovery of the entirety of Farmers’ claims file and certain electronic information; and (3) denied a motion to amend her complaint to include a claim for punitive damages. The Idaho Supreme Court, after review of the terms of the insurance contract and the district court record, affirmed the grant of summary judgment on Farmers’ motion relating to the bad faith claim: “General conclusions about Farmer’s conduct do not provide the facts needed to overcome summary judgment on the ‘fairly debatable’ element. Thus, the district court did not err in granting Farmers’ motion for summary judgment.” View "Cedillo v. Farmers Ins. Co. of Idaho" on Justia Law

In a quiet title action, a landowner brought suit against a lender to extinguish a deed of trust that was recorded against the landowner’s property. The landowner claimed that the lender’s time to foreclose the deed of trust had expired. The district court denied a motion to enter default judgment in favor of the landowner, finding, among other things, that the statute of limitations to foreclose the deed of trust had not run. The district court entered a judgment dismissing the landowner’s suit. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s judgment. View "CMJ Properties v. JP Morgan Chase Bank" on Justia Law

At issue in this matter was landowners’ recourse against an irrigation district for diverting a portion of their water source to other landowners within the district. The appellants-landowners owned farms in Jerome County; A&B Irrigation District (the “District”) distributed water to these farms and others throughout its service area in Jerome and Minidoka Counties. The District serves two distinct sub-areas in its district: Unit A and Unit B. The water the District distributes comes from two sources: (1) surface water from the Snake River and associated reservoirs, and (2) groundwater from the Eastern Snake Plain Aquifer. These two water sources were historically what separated Units A and B, and many owners based their land choices in the 1950s on the water source. Unit A farms have received surface water exclusively since the District’s inception. For decades Unit B farms received only groundwater, but the District converted approximately 1400 Unit B acres to surface water in the 1990s in response to decreasing groundwater supply. Appellants claimed the Project primarily benefited Unit B landowners at the expense of Unit A by diverting a portion of Unit A’s sole water source (surface water) onto Unit B land and “diluting” their annual water supply. Additionally, the District divided Project costs equally among all landowners despite what Appellants claim was the Project’s primary purpose: to help sustain Unit B farms as their groundwater supply continues to decline. The landowners brought an action for a declaratory judgment regarding their constitutional water and property rights. They also sought injunctive relief against the irrigation district for a breach of fiduciary duty. The district court granted the irrigation district’s motion to dismiss on all three of the landowners’ claims. The landowners’ appeal centered on two issues with respect to their three claims against the District: the legal standard under which the district court dismissed Appellants’ claims, and the court’s substantive determinations under that standard. Appellants contend the district court erred both procedurally and substantively in dismissing all three counts in its amended complaint. Procedurally, they claimed the district court improperly considered matters outside the pleadings in dismissing all three claims under Rule 12(b)(6), rather than converting to the Rule 56 summary judgment standard. Substantively, Appellants contended that Counts I and III were justiciable as presented on the face of their amended complaint, and that res judicata did not bar relief under Count II. The Idaho Supreme Court found after review that the landowners failed to demonstrate justiciable claims in their Counts I and III, and that the district court erred in dismissing their property rights claim in Count II by considering matters outside the pleadings under Rule 12(b)(6). View "Paslay v. A&B Irrigation District" on Justia Law