Justia Idaho Supreme Court Opinion Summaries

John Doe, a Washington resident and registered sex offender in Washington, sought a declaratory judgment in Idaho as to whether he could be required to register with the Idaho Sex Offender Registry because of his Washington offenses. Doe’s work opportunities required him to spend more than 30 days a year in Idaho, but he had been spending less time than that in Idaho so as not to trigger a registration requirement. Doe was contemplating relocating to Idaho. Doe sought the court’s determination of whether his Washington offenses were “substantially equivalent” to an Idaho sex offense that required registration when an out-of-state offender moves to or is employed in Idaho. The district court, following a hearing, dismissed the Petition, finding that Doe did not have standing, as he demonstrated no injury in fact and his claim was based on hypothetical facts because he did not yet live here. Additionally, the court found there was also no injury because Doe had not been required to register, nor was there any threatened harm because Doe had not been threatened with prosecution for failing to register. Upon review, the Idaho Supreme Court concluded the district court erred in dismissing Doe's case for lack of standing. Furthermore, the Court ruled that the Washington statutes were "substantially equivalent." View "Doe v. Idaho Sex Offender Registry" on Justia Law

Judy and Dennis Charney were divorced in March 2012. In May, Dennis commenced proceedings against Judy alleging multiple counts of contempt for allegedly violating provisions of the property settlement agreement, which was incorporated into the divorce judgment. Judy denied the allegations and the matter was set for an evidentiary hearing to commence on April 11, 2013. On March 28, 2013, Dennis filed a motion to dismiss the contempt proceedings, which was heard April 9, 2013. The magistrate court asked Judy's attorney whether there was any objection to the motion, and he stated that there was not, but it should be dismissed with prejudice. The court stated that the dismissal would be without prejudice unless the parties agreed that it was with prejudice. Dennis's attorney stated that he did not anticipate the contempt proceedings being refiled, but did not have the authority to agree to a dismissal with prejudice. The court then stated that the dismissal would be without prejudice. The court entered an order dismissing the contempt proceedings the following day. Several days later, Judy moved for attorney fees and costs. Dennis objected, and the matter was argued in July. The magistrate court entered a judgment finding that Judy was the prevailing party in the contempt proceedings and awarded her attorney fees. Dennis challenged the award of attorney fees. The district court ultimately affirmed the award of attorney fees. Approximately two years after Dennis first brought proceedings against Judy, he appealed the affirmance of fees to the Supreme Court. Finding no abuse of discretion in the award of fees, the Supreme Court affirmed. View "Charney v. Charney" on Justia Law

The State of Idaho appealed a district court judgment denying its motion to vacate portions of a Stipulated Partial Settlement and Award entered by an arbitration panel. This case stemmed from the 1998 Tobacco Master Settlement Agreement, wherein certain cigarette manufacturers entered into an agreement with the State to pay damages for the cost of treating smoking-related illnesses. A dispute arose between the parties as to the amount owed in 2003 and the district court entered an order compelling arbitration. The arbitration panel entered a Stipulated Partial Settlement and Award in March of 2013. In June of 2013, the State moved the district court to vacate, modify, or correct the award. The district court concluded the State did not have standing to move to vacate or modify the award. The State appealed. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Philip Morris, Inc." on Justia Law

Plaintiff-appellant Gary Holdaway filed suit against Broulim’s Supermarket, alleging that a titanium screw implanted in his leg was fractured when an automatic door at Broulim’s malfunctioned and closed on the leg. Broulim’s filed a motion for summary judgment arguing that Holdaway failed to provide admissible evidence that the malfunctioning door fractured the screw and caused the resulting medical complications. The district court agreed, granted the motion, and Holdaway appealed. Finding no reversible error, the Supreme Court affirmed. View "Holdaway v. Broulim's Supermarket" on Justia Law

Because no final judgment dissolving the marriage and no judgment regarding custody had ever been entered in this divorce action during the four-year period after the divorce trial, the Supreme Court dismissed the appeal because it did not qualify for an appeal by permission. After the appeal was dismissed, the magistrate court entered a partial judgment purporting to retroactively divorce the parties four years earlier and a partial judgment regarding custody and the division of property and debts. The appellant then filed a motion seeking reconsideration of the order dismissing the appeal. The Supreme Court denied that motion, vacated the partial judgment retroactively terminating the parties’ marriage, and direct the magistrate court to enter a new partial judgment dissolving their marriage. View "Cook v. Arias" on Justia Law

This appeal stemmed from a 1983 Ground Lease of property in Pocatello which Quail Ridge Medical Investors, LLC (Quail Ridge) leased from Pocatello Hospital, LLC d/b/a Portneuf Medical Centers, LLC (PMC). Previously, Quail Ridge appealed a declaratory judgment entered by the district court which found PMC was entitled to an adjustment in the annual rent owed by Quail Ridge from $9,562.50 annually to $148,500 annually, and that Quail Ridge was obligated to pay PMC $416,812.50 in rent for the period at issue. The Supreme Court affirmed the court’s declaratory judgment. While the first appeal was pending, PMC filed a new action seeking payment of the adjusted rents. In the second action, the district court found on summary judgment that Quail Ridge breached the Ground Lease by failing to pay the adjusted rents. Quail Ridge appealed, arguing the breach of contract and breach of guarantee claims are barred under res judicata. Finding no reversible error, the Supreme Court affirmed. View "Pocatello Hospital v. Quail Ridge Medical Investor" on Justia Law

This case arose out of a professional negligence claim relating to a life insurance policy. Bill Gailey purchased the life insurance policy from Kim Whiting in 2010. In August 2011, Gailey cashed in the life insurance policy after receiving advice from Whiting to that end. Gailey suffered negative tax consequences from cashing in the policy and subsequently filed a complaint against Whiting alleging Whiting was negligent when he advised Gailey to cash in his policy without warning him of the potential tax consequences. Whiting subsequently moved the court to dismiss the action for lack of personal jurisdiction because Whiting no longer lived in Idaho, Gailey was a resident of Oregon, and the alleged tort did not occur in Idaho. The district court granted Whiting’s motion and Gailey appealed to this Court. Finding no reversible error, the Supreme Court affirmed. View "Gailey v. Whiting" on Justia Law

Franklin Building Supply Co., Inc. (“FBS”) filed suit against Aaron Michael Hymas to recover money owed on an open account for construction supplies, equipment, and labor supplied to Crestwood Construction, Inc. FBS claims that Hymas guarantied any unpaid balance on Crestwood’s account. The district court granted FBS’s motion for summary judgment. Shortly thereafter, the district court permitted FBS to correct an error in an affidavit submitted in support of summary judgment regarding the amount of interest owed on the outstanding balance. Hymas twice moved the court to reconsider its order granting summary judgment and the district court denied both motions. He timely appealed. Finding no reversible error, however, the Supreme Court affirmed. View "Franklin Building Supply Co. v. Hymas" on Justia Law

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