Justia Idaho Supreme Court Opinion Summaries

In 2018, Terri Richardson Mattson (“Mattson”) and her husband filed this action against the Idaho Department of Health and Welfare, and its employee, Laurie Gallegos, a certified physician assistant (“Defendants”), alleging medical malpractice and failure to obtain informed consent related to outpatient mental health services Mattson received from Defendants. As a part of those services, Gallegos prescribed Mattson Prozac (fluoxetine), an antidepressant. Roughly one month later, the day of her follow up appointment with Gallegos, Mattson woke up, took a firearm from her gun cabinet, went to the liquor store, bought a bottle of vodka, drank the entire bottle while driving to her follow up appointment, and when she arrived in the Department’s parking lot, fired the gun into her head. Mattson survived but suffered extensive injuries. Subsequently, Mattson and her husband filed this action. The district court granted summary judgment to Defendants on two grounds: (1) Defendants were immune from liability under the Idaho Tort Claims Act (“ITCA”) because Mattson’s claims arose out of injuries sustained while she was receiving services from a “mental health center”; and (2) the “reckless, willful and wanton conduct” exception to immunity did not apply as a matter of law. The Idaho Supreme Court affirmed the district court’s decision that Mattson’s and her husband’s claims fell within the purview of the “mental health center, hospital or similar facility” immunity provision in Idaho Code section 6-904A(2). However, the Court reversed the district court’s decision that there was no triable jury question under the “reckless, willful and wanton conduct” exception to immunity. The Supreme Court found Mattson alleged sufficient facts at summary judgment to demonstrate that a reasonable person could find that Defendants’ acts or omissions were “reckless, willful and wanton[.]” Thus, the Court vacated the judgment and remanded this case for further proceedings. View "Mattson v. IDHW" on Justia Law

A coalition of media companies petitioned the Idaho Supreme Court for a writ of mandamus or a writ of prohibition to vacate a nondissemination order issued by the magistrate court in the pending criminal action of State of Idaho v. Bryan C. Kohberger. The Supreme Court expedited the case and ordered briefing from the parties. The Court also granted motions to intervene filed by the two parties to this case, the State of Idaho, Latah County Prosecutor (“the State”) and the defendant, Bryan Kohberger, who were also permitted to file briefs. After review of the briefs submitted, the Supreme Court dispensed with oral argument was unnecessary to resolve this case. The underlying case involved the 2022 murder of four University of Idaho students, for which Kohberger was arrested and charged with committing. The case drew widespread publicity. Recognizing the high-profile nature of the case and the extensive coverage it has received, along with the need to minimize possible pretrial prejudice, Kohberger’s attorneys and the attorneys for the State stipulated to the nondissemination order. Shortly after the order was entered, the medial companies challenged the constitutionality of the mondissemination order and sought extraordinary relief to protect free speech rights and the media’s ability to cover the case under the U.S. and Idaho Constitutions. The Supreme Court ultimately concluded that neither a writ of mandamus nor a writ of prohibition were appropriate remedies at this time. View "Associated Press, et al. v. Second Judicial District, et al." on Justia Law

A group of pro se aggrieved property owners dubbed “Riverton Citizens Group,” timely filed a petition for judicial review challenging the Bingham County Commissioners’ (“the County”) decision to grant a zone change request. The caption of the petition named “Riverton Citizens Group” as the pro se petitioner, but the body of the petition then named the aggrieved property owners individually as the parties petitioning the County’s decision, while also providing that they were proceeding pro se under the title of “Riverton Citizens Group.” The petition was not signed by any of the aggrieved property owners. Instead, it was signed by a non-petitioner who purported to be the “agent” for “Riverton Citizens Group.” The purported “agent” was not licensed to practice law in Idaho. After the district court entered a notice of intent to dismiss the petition because Riverton Citizens Group was not represented by counsel, the aggrieved property owners attempted to correct the petition through five subsequent filings, each signed by only one of the aggrieved property owners. The district court subsequently issued a written decision, concluding the petition was “improperly filed” and therefore was not a “petition” that invoked the district court’s subject matter jurisdiction under Idaho Rule of Civil Procedure 84(n). Because the time for filing a new “petition” under I.R.C.P. 84(n) had passed, the district court dismissed the case with prejudice—reasoning it no longer had jurisdiction. A licensed attorney did not appear on behalf of the aggrieved property owners until after the district court’s decision to dismiss. The Idaho Supreme Court vacated the district court’s order: “the errors in the caption and the omitted signatures were not fatal or so defective as to render the petition a nullity or ‘improperly filed’ such that the district court had no subject matter jurisdiction. Instead, these errors may be corrected through a filing or amended petition on remand that relates back to the date of the timely petition.” View "Riverton Citizens Group v. Bingham County Commissioners" on Justia Law

This case concerned a partition action: the district court determined that a physical partition of the property would result in great prejudice and ordered the parties to sell the property and split the proceeds equally. Kay Kiebert appealed the district court’s order, arguing that the district court utilized the wrong standard for determining whether “great prejudice” would result from a physical partition and that it also relied on inappropriate considerations in determining that great prejudice would result. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s order. View "Nordgaarden v. Kiebert" on Justia Law

Appellants Brett and Jenny Terrell appealed a district court’s decision to grant Respondent Paradis de Golf Holding, LLC attorney fees under Idaho Code section 12-120(3). In February 2020, the “Terrells”) sued Paradis for an alleged violation of a recreational easement. In early 2004, Prairie Golf, LLC conveyed to BRMC, LLC a “perpetual, nonexclusive ‘recreational easement’ upon, over, through and across [Prairie Golf’s] property[.]” The easement was appurtenant to and ran with BRMC’s property, which was to be subdivided into 52 single-family residential lots (“the Grayling Estates subdivision”). The easement instrument stated that “each purchaser/owner of a Lot shall be entitled to the benefit of this easement,” which included the ability to play golf for free at a nearby golf course owned at the time by Prairie Golf. In early 2006, the Terrells purchased a home in the Grayling Estates subdivision, which benefitted from the recreational easement. In April 2014, Paradis acquired the golf course subject to the recreational easement. In 2019, Paradis began developing property within the golf course boundary area, which included converting a par five hole to a par three hole and removing a driving range. Paradis then developed residential lots on the excess property where the driving range and part of the par five golf hole used to be. Believing that these developments infringed upon their easement rights, the Terrells sued Paradis. The parties proceeded to arbitration for resolution of their dispute. The arbitrator rendered a decision in Paradis’ favor, finding that none of Paradis’ alterations to the golf course infringed upon the Terrells’ easement rights. Following the arbitration proceedings, Paradis moved for attorney fees under Idaho Code section 12-120(3). The Idaho Supreme Court found the district court erred in concluding that an award of fees was appropriate under section 12-120(3): "Our caselaw is clear that transactions for personal or household purposes do not constitute a commercial transaction for purposes of section 12-120(3)." View "Terrell v. Paradis de Golf Holding, LLC" on Justia Law

This appeal concerned the existence of an easement across a lot (“Lot 20”) in the Greenbriar Estates subdivision. In 2004, John Esposito acquired two adjacent parcels of land. The northern parcel contained a mini storage unit for use by the residents of the Greenbriar Estates (the “Mini Storage Lot”), while Esposito planned to develop the southern parcel into a recreational vehicle storage lot1 (the “RV Lot”) and to additionally build several more homes. The only access to the planned RV Lot at the time of severance was through the northern parcel. However, no access easement either existed or was created at the time that the northern and southern parcels were severed from the Greenbriar subdivision. Once he completed the development of the subdivision, Esposito quitclaimed the common areas within the subdivision to the Greenbriar Estates Homeowners’ Association (the “HOA”). The HOA subsequently contested Esposito’s use of Lot 20 to access the RV Lot. After Esposito and the HOA began litigating this dispute, the parties entered into two partial settlement agreements: one in 2012 and the second in 2014. In 2013, during the ongoing litigation, Esposito defaulted on his payments for the RV Lot and mortgage-holder D.L. Evans Bank foreclosed. In 2014, Esposito, who no longer owned the RV Lot, settled all existing claims with the HOA in the 2014 total settlement agreement; however, the 2014 agreement did not refer to the RV Lot. Several years later after executing the 2014 settlement agreement, Esposito reacquired the RV Lot from the Bank and resumed his efforts to transform the parcel into RV storage and additional homesites. Once Esposito began developing the RV Lot and using Lot 20 to access it, the HOA again filed suit in district court, alleging Esposito had no right to use Lot 20. The district court granted the HOA’s request to quiet title to Lot 20 but denied the HOA’s request for attorney fees. Esposito and the HOA both appealed the district court’s decisions. Finding no reversible error in the district court's decision, the Idaho Supreme Court affirmed. View "Greenbriar Estates Homeowners' Association, Inc. v. Esposito" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on a residence in the Boise foothills that was damaged by a landslide, which ultimately prevented the builder from obtaining a certificate of occupancy. BrunoBuilt, Inc., the general contractor of the project, sued multiple parties, including Erstad Architects, PA, the architectural firm for the project, Andrew Erstad, the principal architect, and Cheryl Pearse, the project manager from Erstad Architects, PA (collectively, Defendants), for professional negligence in connection with work completed for construction of the residence. Defendants successfully moved for summary judgment on the basis that the two-year statute of limitations in Idaho Code section 5-219(4) barred BrunoBuilt’s claim. Two years after the district court issued its memorandum decision and order granting summary judgment, BrunoBuilt moved the district court for reconsideration, citing new evidence and arguments. The district court denied the motion for reconsideration, concluding it was “untimely, lacking in diligence, and improper.” BrunoBuilt then appealed, challenging the decision of the district court on summary judgment and additionally asserting that the court erred in an earlier order deconsolidating the cases with other defendants. Prior to oral argument, Defendants moved the Supreme Court to sanction counsel for BrunoBuilt pursuant to Idaho Appellate Rule 11.2 for non-disclosure of material procedural facts in its opening brief. After review, the Supreme Court affirmed the district court’s decision granting summary judgment against BrunoBuilt, and agreed that the conduct of BrunoBuilt’s attorney on appeal ran afoul of Rule 11.2, and imposed sanctions. View "BrunoBuilt, Inc. v. Erstad Architects, PA" on Justia Law

Appellants were residents of Blaine County, Idaho (the “County”) who opposed a modified conditional use permit that the County granted to Idaho Power to install above-ground power lines. After the County denied Petitioners’ motion to reconsider as untimely, Petitioners sought judicial review of the permit in district court. Intervenor, Idaho Power Company, filed a motion to dismiss the petition, which the County joined, arguing that Petitioners’ underlying motion to reconsider was untimely, thereby precluding the district court from exercising its jurisdiction over the petition. The district court granted the motion to dismiss and concluded that it lacked jurisdiction to consider the petition because the Local Land Use and Planning Act (LLUPA) required aggrieved parties to file a timely motion to reconsider prior to seeking judicial review. The district court further held that no exception to the exhaustion of administrative remedies doctrine applied. Petitioners timely appealed to the Idaho Supreme Court to resolve the question of whether the LLUPA required a timely motion to reconsider to be filed in advance of a petition for judicial review. The Supreme Court concluded the act does require the filing of a timely motion to reconsider in advance of a petition for judicial review, and, therefore, affirmed the district court's order. View "Richardson v. Blaine County" on Justia Law

BrunoBuilt, Inc., was constructing a custom home on a vacant lot in 2016 when a landslide occurred beneath the Terra Nativa subdivision in the Boise foothills. Following damage to the lot, BrunoBuilt filed a professional negligence suit against numerous engineers and engineering firms involved in the construction of the subdivision, arguing that they failed to identify preexisting landslide conditions and other geological circumstances that made residential development unsafe at this site. In the fall of 2018, BrunoBuilt discovered additional damage to the finished custom home itself. It then brought suit against additional defendants, including Briggs Engineering, Inc., and Erstad Architects. Briggs Engineering moved for summary judgment, which the district court granted. The court concluded that BrunoBuilt’s action was time barred by the two-year statute of limitations under Idaho Code section 5-219(4). BrunoBuilt appealed this decision, arguing that the malpractice claim did not begin to accrue until there was damage to the custom home, rather than just the land. To this the Idaho Supreme Court disagreed with BrunoBuilt’s analysis and affirmed the district court that BrunoBuilt’s claim was time barred. View "Brunobuilt, Inc. v. Briggs Engineering, Inc." on Justia Law

Jane Doe, a three-year-old child, was in the custody of the Idaho Department of Health and Welfare (the “Department”); she was six days shy of her first birthday when the State removed her from the custody of her mother and placed her with a foster family. Her mother’s attempts to stick to a permanency plan were inconsistent, and while for the majority of the life of this case, the magistrate court held fast to a permanency goal of reunification, it modified that goal in the summer of 2022 so that termination of parental rights and adoption became the primary goals for Jane and reunification became the concurrent goal. Mother appealed the district court’s change of the permanency goals. She also sought a permissive appeal from the magistrate court to appeal to the district court. The magistrate court granted the motion. The district court dismissed the case and remanded it back to the magistrate court sua sponte after determining it did not have jurisdiction to hear the appeal. Mother then appealed to the Idaho Supreme Court. The Supreme Court found no error in the district court’s judgment and affirmed. View "IDHW v. Jane Doe (2022-36)" on Justia Law