Justia Idaho Supreme Court Opinion Summaries

The issue this case presented for the Idaho Supreme Court’s review centered on a judgment dismissing claims against an attorney and a law firm that he later joined based upon an opinion letter issued by the attorney in his capacity as corporate counsel regarding the legality of a stock redemption agreement. The Appellant challenged the grant of summary judgment to the Respondents (attorney and law firm) and the amount of attorney fees awarded to them. After review, the Supreme Court affirmed the judgment dismissing the claims and the awards of attorney fees, and awarded attorney fees on appeal. View "Taylor v. Riley" on Justia Law

The Idaho Supreme Court addressed the issue of whether a prescriptive easement across a parcel of land was extinguished by operation of former Idaho Code section 63-10091 when that parcel was sold by tax deed. 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 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, finding 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 Supreme Court held that the deed should not be reformed, vacated a portion of the district court’s judgment, and remanded 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. The Regans appealed, but shortly after filing, the Idaho Legislature amended Idaho Code section 63-1009. The new version of 63-1009 did not apply retroactively, and the Supreme Court determined the trial court was correct in finding any prescriptive easement was extinguished by the old law. View "Regan v. Owen" on Justia Law

This case involved Arthur Watkins’ (Father) attempt to recover damages based on a default by his son, Arnold Douglas Watkins (Son or Doug), under a real estate installment contract. The question presented for the Idaho Supreme Court’s review was whether the complaint gave adequate notice of the election to accelerate the debt as required by Washington law. Son also brought a counterclaim for breach of a compensation agreement executed by a sibling acting on behalf of Father using a power of attorney. The compensation agreement purported to obligate Father to pay Son $3,000 per month for life. Father argued that the compensation agreement lacked consideration. The district court held a bench trial and ultimately found in favor of Father on his breach of contract claim and on the counterclaim brought against him. Son appealed. The Supreme Court found that the district court: (1) erred in concluding Father was not required to give notice of the acceleration; and (2) was correct in concluding the compensation agreement was unenforceable for lack of consideration. View "Watkins v. Watkins" on Justia Law

Sharon Hammer appealed a district court’s order dismissing her complaint. Hammer’s action against Nils Ribi alleged that he assaulted her during a city council meeting on September 15, 2011. Hammer was employed as City Administrator for Sun Valley, and Ribi was a member of the city council. Hammer’s alleged that, during a break in the meeting, Hammer left the council chambers to copy some documents. Ribi followed Hammer and demanded that she make certain changes to budget documents. Hammer refused. Ribi raised his arms; Hammer was afraid Ribi was going to hit her, and she stepped back. Hammer’s complaint alleged that Ribi had committed a civil assault. The district court granted Ribi’s motion to dismiss for failure to state a claim upon which relief could be granted. The district court denied Hammer’s motion to require Ribi to undergo a mental examination and ruled that Hammer failed to plead facts which would show that Ribi was not immune from suit under the Idaho Tort Claims Act (ITCA). The Idaho Supreme Court concluded the district court erred in dismissing Hammer's complaint for failing to state a claim. The district court did not abuse its discretion in denying Hammer's motion to compel a mental health examination. The Supreme Court vacated the judgment dismissing Hammer’s lawsuit and remanded for further proceedings. View "Hammer v. Ribi" on Justia Law

Shawn Bailey sued several parties, including Peritus I Assets Management, LLC (Peritus), for claims allegedly arising out of his employment at American Medical File, Inc. (AMF), doing business as OnFile. Bailey alleged claims for breach of his employment contract and intentional infliction of emotional distress. Peritus moved to dismiss Bailey’s claim for intentional infliction of and the district court granted the motion on the basis that Bailey had not alleged conduct that was extreme and outrageous. Peritus thereafter moved for summary judgment on Bailey’s breach of contract claim, contending the statute of frauds rendered it unenforceable. In response, Bailey moved to amend his complaint in an effort to bypass the statute of frauds. The district court denied Bailey leave to amend and granted Peritus summary judgment, finding the statute of frauds dispositive. Bailey appealed the denial of leave to amend and grant of summary judgment in favor of Peritus. The Idaho Supreme Court found the district court erred by finding the statute of frauds barred Bailey’s breach of contract claim against Peritus, “[Bailey’s] lone allegation does not vitiate the thrust of Bailey’s complaint to somehow change this case from one alleging principal liability to one alleging collateral liability.” The Court’s conclusion that the statute of frauds did not apply to Bailey’s claim for breach of contract against Peritus as alleged in his initial complaint mooted any need for Bailey to allege statute of frauds exceptions, and the Supreme Court did not address that issue. View "Bailey v. Peritus I Assets Management" on Justia Law

Perry Krinitt, Sr. appealed the district court’s grant of summary judgment in favor of the State of Idaho and the Department of Fish and Game (IDFG). Perry Krinitt, Jr. (“Perry”) was a pilot for Leading Edge Aviation. He died when the helicopter he was piloting crashed in Kamiah, Idaho. Perry was flying IDFG employees Larry Bennett and Danielle Schiff to conduct a fish survey on the Selway River. Bennett and Schiff also died in the crash. An investigation revealed that the accident was caused when a clipboard struck the tail rotor: one of the passengers became sick and opened the helicopter door, dropping the clipboard in the process. Krinitt filed a wrongful death suit based in negligence seeking damages against IDFG for Perry’s death. IDFG did not assert statutory immunity under Idaho’s Worker’s Compensation Act as a defense. IDFG moved for summary judgment on grounds that Krinitt could not prove negligence. The district court ruled that IDFG was a statutory employer under the Idaho Worker’s Compensation Act and, consequently, IDFG was entitled to immunity from actions based on the work-related death of Perry. Krinitt appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Krinitt v. Idaho Dept of Fish & Game" 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 essentially cut off their property from the development by building a park and planting trees between their lot and the nearby street and development, and in doing so: (1) breached a contract; (2) breached an express warranty; (3) breached their duty of good faith and fair dealing; (4) violated the Idaho Consumer Protection Act; and (5) made false representations. 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 limitation. The crux of the Swaffords’ action is that Huntsman Springs breached the Contract by failing to develop the surrounding area in conformance with the Master Plan of the development, i.e., by constructing the park that separated their property from the rest of the development. The Idaho Supreme Court determined the Master Plan was not incorporated or referenced by the Swaffords' Contract; therefore, it did not contractually obligate Huntsman Springs. Accordingly, the Court affirmed the district court's judgment in favor of Huntsman Springs. View "Swafford v. Huntsman Springs" on Justia Law

Ashley Palmer (Palmer) and Stephen Palmer appealed a district court’s order granting Lisa Ellefson’s motion for a new trial under Idaho Rule of Civil Procedure 59(a)(6). Ellefson was involved in an automobile accident caused by Palmer. A jury found that Ellefson was not injured in the accident. However, the district court determined that the jury verdict of “no injury” was against the clear weight of evidence and granted a new trial subject to an additur in the amount of $50,000. On appeal, Palmer argued that the district court abused its discretion in granting the new trial and in setting additur at $50,000. Finding no such error, the Idaho Supreme Court affirmed. View "Ellefson v. Palmer" on Justia Law

This case was previously before the Idaho Supreme Court in In Matter of Doe (2016-14), 389 P.3d 141 (2016). There, the Court vacated the judgment terminating Jane Doe’s parental rights to her son M.R. and remanded the case for further findings of fact and conclusions of law. On remand, the magistrate court again terminated Doe’s parental rights. The magistrate court found that M.R. was neglected as defined by Idaho Code sections 16-2002(3)(a) and 16-2002(3)(b) and that Doe’s compliance with her case plan was not impossible. Doe timely appealed. Finding no reversible error, the Supreme Court affirmed. View "H & W v. Jane Doe (2017-3)" on Justia Law

At issue in this case was the modification of a default judgment requiring that the parents of a child rotate custody of their three-year-old child every three weeks. The father lived in Blackfoot; the mother lived out of state in Oceanside, California (913 miles away). The Idaho Supreme Court held that the magistrate court abused its discretion in ordering that custody rotation. In addition, the mother had moved to modify the judgment by default, but did not move to set aside the entry of default. The Supreme Court held that the father waived the default by litigating the motion to modify. View "Martinez v. Carrasco" on Justia Law