Justia Idaho Supreme Court Opinion Summaries

Mercedes Turner filed suit against her former employer, the City of Lapwai, claiming that she was owed unpaid compensation and reimbursement for certain expenses incurred during her employment. The City moved for summary judgment, arguing that Turner’s claim for unpaid compensation was barred by the applicable statute of limitations and that both claims were barred because Turner failed to provide adequate notice of her claims as required by Idaho Code section 50-219. The district court granted summary judgment in favor of the City, holding that Turner failed to provide adequate notice of her claims. Turner appealed. Upon review, the Supreme Court affirmed because Turner failed to file her claim with the city clerk as required by Idaho Code sections 50-219 and 6-906. Consequently, the other issues raised on appeal by Turner and the City were not addressed. View "Turner v. City of Lapwai" on Justia Law

Christian Westby, James Westby, and Kristina Westby appealed the district court’s denial of their motion to reconsider the court’s protective order granted to Mercy Medical Center and Dr. Gregory Schaefer. This case arose from the Westbys’ claim that Dr. Schaefer’s and Mercy Medical’s negligence resulted in lifelong brain damage to Christian Westby. Near the end of discovery, the district court granted Mercy Medical and Dr. Schaefer’s protective order motion to prohibit the Westbys from deposing Mercy Medical and Dr. Schaefer’s expert witnesses. The district court later denied the Westbys’ motion to reconsider that protective order. The Westbys argued on appeal to the Supreme Court that the district court abused its discretion by not requiring any showing of good cause or unreasonable delay and basing its decision on a mistaken belief that the Westbys were dilatory. The Supreme Court agreed that the trial court erred, vacated the order and remanded the case for further proceedings. View "Westby, et al v. Schaefer, M.D." on Justia Law

At the center of this appeal was ABC Agra, LLC's action seeking a declaratory judgment against Critical Access Group, Inc. ("CAG") regarding the enforceability of a real property use restriction. Because there were no existing or proposed uses that implicated the restriction, the district court determined that the claim was not ripe and granted CAG's 12(b)(6) motion to dismiss. Finding no reversible error, the Supreme Court affirmed this dismissal. View "ABC Agra v. Critical Access Group" on Justia Law

Crystal Edgar and Brad Carr were the parents of D.C., born in 2003. Edgar and Carr were never married. Both Edgar and Carr have served in the Idaho National Guard since D.C.'s birth, resulting in custody disputes arising from the parties' deployments. Edgar's contempt convictions arose from Carr's allegation that Edgar committed two separate violations of the parties' Parenting Plan, which was incorporated into the magistrate court's Order for Entry of Stipulation for Decree Regarding Paternity, Child Custody and Child Support (the May 12 Order). The magistrate court heard Carr's contempt allegations, and found Edgar guilty on two counts. On Count I, the magistrate court sentenced Edgar to five days jail, suspended, a $5,000 fine, suspended, and placed her on two years unsupervised probation. On Count III, the magistrate court sentenced Edgar to three days in jail, to be served immediately. More than a month later, and after Edgar had completed serving her jail time, the magistrate court entered its Judgment of Contempt and found that Edgar "willfully violated the court order that specifically provided that decisions concerning which school [D.C.] would attend be made jointly by the parties." The magistrate court also concluded that Edgar "blatantly breached her obligation of good faith and fair dealing when she summarily denied [Carr's] last chance to see his son before being sent to a war zone where many fathers have not returned." Edgar appealed. The district court issued its Memorandum Decision and affirmed the magistrate court's decision. Upon review, the Supreme Court concluded the magistrate court erred by convicting Edgar of contempt on a basis different from that which was alleged in Carr's affidavit and the district court erred in affirming that conviction. Accordingly, the Court reversed the judgment of conviction. View "Carr v. Edgar" on Justia Law

Dennis Sallaz and Renee Baird were married in Oregon in 1996. Baird filed for divorce in Idaho in 2004. The magistrate court entered a partial decree at the request of the parties, granting the divorce in 2005. The decree included a certificate in accordance with Idaho Rule of Civil Procedure (I.R.C.P.) 54(b) certifying the decree as a final judgment upon which execution may issue and an appeal may be taken. Neither party ever appealed from the certified judgment. The magistrate court conducted a subsequent trial regarding the division of property and debts, and issued its amended findings of fact and conclusions of law in 2007. After several post-trial motions, the magistrate court entered an amended order in 2012, settling property and debt issues. Sallaz filed a notice of appeal to the district court a few months later. Then Baird filed for Chapter 7 relief in bankruptcy. The filing of the bankruptcy petition stayed the appeal in the district court until Sallaz received permission from the bankruptcy court to pursue the appeal. Jeremy Gugino, the bankruptcy trustee, intervened in the appeal as a real party in interest. While the appeal from the magistrate's division was pending before the district court sitting in its capacity as the intermediate appellate court, Sallaz filed an independent action in Ada County asserting for the first time that the Oregon marriage was invalid. The bankruptcy trustee intervened and filed a motion to dismiss the action on the basis that it was an impermissible collateral attack on the magistrate court's property settlement order. Sallaz then requested that the district court, as the intermediate appellate court, remand the case to the magistrate division to determine the validity of the marriage. The district court held that Sallaz's challenge to the validity of the marriage was untimely, that Sallaz had impermissibly raised an issue for the first time on appeal, and that Sallaz was estopped by his inconsistent positions from challenging the parties' marriage. Sallaz requested that the Supreme Court to remand the case to the magistrate court for a determination regarding the validity of the marriage. The Supreme Court denied Sallaz's motion. Sallaz then appealed the district court's intermediate appellate decision and continued to challenge the validity of the parties' marriage in Oregon. On the intermediate appeal in the district court Sallaz asserted that the marriage was invalid because the marriage ceremony allegedly was performed by an individual who was not authorized to perform marriage ceremonies, and (for the first time), that the marriage ceremony was invalid because no Oregon marriage license could be found of record. Under either theory, Sallaz argued that invalidity of the marriage deprived the magistrate court of subject matter jurisdiction to grant a decree of divorce. Upon review, the Supreme Court affirmed the district court's determination that the magistrate court had subject matter jurisdiction to terminate the parties' marriage and divide the community property. View "Gugino v. Sallaz" on Justia Law

The issue on appeal to the Supreme Court in this case was over attorney fees. Defendants Aeroplanes Over Idaho ("AOI") and Holbrook Maslen were ordered to pay fees over a dispute arising from the claim of lien filed by AOI on a PT-23 Fairchild airplane owned by the Idaho Aviation Hall of Fame ("IAHOF") and transferred to the Idaho Military Historical Society ("IMHS"). Holbrook Maslen, the President of AOI, stored the Fairchild airplane owned by IAHOF for approximately nine months. IAHOF transferred title of the airplane to IMHS. The Defendants refused to surrender possession of the airplane and filed a claim of lien with the FAA seeking compensation for claimed storage and maintenance expenses they incurred on the airplane. IMHS filed suit against the Defendants who counterclaimed against IMHS. After a bench trial, the district court ordered the return of the airplane to IMHS and found that IMHS failed to establish damages on its claims. The district court also found that the Defendants failed to prove their counterclaims. The district court further ruled that AOI and Maslen were jointly liable for attorney fees because the Defendants' defense of this case was frivolous. Defendants appealed. Upon review, the Supreme Court concluded that the trial court record supported the district court's determination that the IMHS was the prevailing party, and that the court did not err in awarding IMHS attorney fees. View "Idaho Military Historical Society v. Maslen" on Justia Law

In 2009, Joseph Pierce filed suit against Steven McMullen and Highland Financial, LLC, seeking damages for various violations of the Idaho Consumer Protection Act and for breach of contract, all based upon an alleged scam in which the Defendants represented that they could protect Pierce from losing his equity in real property that was facing foreclosure. Pierce alleged that the Defendants obtained title to his real property pursuant to a promise to assume the loans secured by the property, to market and sell the property, and to pay him at least $50,000 or more from the sale proceeds, depending upon the sale price. He claimed that he deeded the property to the Defendants, that they failed to make the payments on the loans, and that the property was sold at a foreclosure sale. The complaint also alleged that Highland Financial was the alter ego of McMullen. Defendants did not appear, and on August 6, 2010, the court entered default against them. Mr. Pierce filed his amended complaint on May 11, 2011. The complaint simply added allegations to support an award of punitive damages. On June 13, 2011, Mr. McMullen filed a notice of appearance on behalf of himself and on behalf of Highland Financial. McMullen filed an answer to the amended complaint in his behalf and on the behalf of Highland Financial. McMullen was not licensed to practice law in Idaho, therefore his appearance on behalf of Highland Financial and the answer he filed on its behalf were nullities. In his answer, McMullen only denied the allegations regarding punitive damages. The case was scheduled for trial to commence on June 18, 2012. Plaintiff appeared with counsel, but the Defendants again did not appear. After discussion with Pierce’s counsel, the district court stated that McMullen "is defaulted, his answer is stricken, and the plaintiff prevails on their [sic] claims," then asked Pierce to present evidence as to damages. Pierce testified as did another alleged victim of. McMullen. At the conclusion of the testimony, Pierce’s counsel filed proposed findings of fact and conclusions of law and a trial brief. The district court then issued its memorandum decision holding that. Pierce failed to prove any of his claims and ordered that his amended complaint be dismissed with prejudice. Pierce timely appealed. Largely because Defendants failed to appear and failed to answer the complaint and the facts of this case were therefore undisputed, the Supreme Court concluded that the district court erred in holding that Pierce did not prove his case. The case was remanded for further proceedings. View "Pierce v. McMullen" on Justia Law

Appellant Marvin Morgan appealed the dismissal of his wrongful death action, as well as an order imposing sanctions against him and his former attorney. Morgan asserted that he was entitled to special and general damages as a result of the wrongful death of his wife, Ella Morgan. In January of 2004, Mrs. Morgan underwent testing at the Idaho Heart Institute in Idaho Falls. After reviewing Mrs. Morgan’s test results, Dr. John Chambers recommended that she return for an angiogram. The Morgans expected that Dr. Chambers would perform the angiogram. Mr. Morgan drove Mrs. Morgan to the Idaho Heart Institute for her scheduled angiogram. Morgan asserts that it was not Dr. Chambers who performed the angiogram, but Dr. Michael Demos, a doctor who neither of the Morgans had ever met. Morgan alleged that Dr. Demos negligently performed the angiogram, "causing a dissection and damage to Mrs. Morgan’s heart and right coronary artery, creating a medical emergency which then necessitated a high-risk medical procedure in an attempt to repair the damage." Mrs. Morgan passed away on February 24, 2004, purportedly because of complications resulting from the angiogram performed by Dr. Demos. The case sat "dormant for a remarkable twenty one months." Due to the inactivity, Mr. Morgan's son filed notice of substitution of counsel, then attempted to reopen the case. Morgan's motion to reopen was ultimately denied, and the case dismissed with prejudice. The Supreme Court concluded the district court did not abuse its discretion for dismissing the case without prejudice, but vacated the sanction against Morgan's former counsel. View "Morgan v. Demos" on Justia Law