Justia Idaho Supreme Court Opinion Summaries

In 2006, during the pendency of divorce proceedings, Charles Earl Guess, his wife, and their respective attorneys agreed that Ms. Guess and her attorney would meet Mr. Guess at the parties’ residence so that they could walk through the house and look in a vault in the house with Mr. Guess present. When Ms. Guess and her attorney arrived at the house, they walked with Mr. Guess into the basement where the vault was located. Mr. Guess allowed his wife and her attorney to walk into the vault first, and then he pulled out a semiautomatic pistol, pointed it at them, and stated that he was going to kill them. While holding the pistol in his right hand, he struck Ms. Guess twice in the face with his left fist. She and her attorney were ultimately able to talk Mr. Guess into putting the gun down. After Ms. Guess and her attorney were able to leave the house, they drove to seek medical care for her and to contact the police. The State charged Mr. Guess with two counts of felony aggravated assault, and one count of misdemeanor battery. Ultimately, he and the State entered into a written plea agreement. The State agreed to file an amended information charging him with one count of aggravated assault alleged to have been committed against both victims, to which he would plead guilty. The State then recommended that he be sentenced to a withheld judgment and be placed on probation for no more than five years, and he could withdraw his guilty plea if the district court was unwilling to impose a sentence consistent with that recommendation. Mr. Guess pled guilty to the charge, and the court imposed a sentence consistent with the written plea agreement, with the period of probation being five years. Mr. Guess appealed the sentence. Finding no abuse of the court's discretion, the Supreme Court affirmed. View "Idaho v. Guess" on Justia Law

This was an action brought by the grantor of a deed of trust to stop nonjudicial foreclosure proceedings based upon the contention that MERS, the Mortgage Electronic Registration Systems, which was the named beneficiary as nominee for the lender, could not legally act as the beneficiary. The defendants moved to dismiss this action on the ground that the complaint did not state a claim upon which relief could be granted. The district court agreed and entered judgment in favor of the defendants. Upon review, the Supreme Court affirmed the district court's judgment. View "Edwards v. MERS" on Justia Law

In 2011, Administrative District Judge Nye issued an Administrative Order Declaring Petitioner Holli Telford a Vexatious Litigant. At the time the pre-filing order was issued, there were no proceedings before Judge Nye to which Telford was a party. Judge Nye issued the pre-filing order after receiving requests from several district court and magistrate judges. The pre-filing order declared Telford a vexatious litigant on the basis that she "has previously been declared to be a vexatious litigant by any federal court of record in any action or proceeding." Telford had been declared vexatious by Utah, Texas, the Federal Ninth Circuit Court of Appeals, the Federal District Court of Idaho, the Federal District Court of Montana, and the United States Supreme Court. The pre-filing order also found Telford to be a vexatious litigant on the additional basis that she has commenced in Idaho three or more pro se litigations that were determined adversely to her in the past seven years. Telford was then served the pre-filing order. On appeal, Telford challenged the order deeming her a vexatious litigant, including attacking the merits of cases underlying the declarations of the other jurisdictions. Upon review, the Idaho Supreme Court found no abuse of discretion, and affirmed Judge Nye's pre-filing order. View "Telford v. Nye" on Justia Law

In 2007, Employers Mutual Casualty Company (EMC) brought a declaratory judgment action against the Donnellys and Rimar Construction, Inc. (RMI) to establish that under its policy of insurance with RCI, EMC had no duty or responsibility to pay damages claimed by the Donnellys in litigation between the Donnellys and RCI. The declaratory judgment action was stayed until a verdict was reached in the underlying action. In the underlying action, the Donnellys were awarded damages, costs and attorney fees against RCI. Subsequently the district court entered summary judgment in the declaratory action, finding that there was no insurance coverage for the damages the Donnellys incurred, but that there was coverage for costs and attorney fees. On appeal, EMC argued that the district court erred in its determination that it had a duty to pay attorney fees and costs when there were no damages awarded to the plaintiff subject to the policy coverage. The Donnellys cross appealed, arguing the district court erred in its conclusion that EMC did not have a duty to cover the damages in this case, and that the Donnellys were entitled to attorney fees. Upon review, the Supreme Court affirmed the district court's decision. View "Employers Mutual Casualty Co v. Donnelly" on Justia Law

The issue before the Supreme Court in this permissive interlocutory appeal was a district court's determination that the law of the case doctrine prohibited it from making a retroactive determination of Defendant-Respondent Faron Hawkins' mental competency when he stood trial in 2008. A jury convicted defendant of two counts of robbery. He appealed his conviction, and the court of appeals vacated the decision and remanded the matter for a new trial. The appellate court determined that the district court erred by not having defendant undergo a mental health evaluation during his jury trial to determine whether or not he was competent to proceed. Based on the totality of the evidence presented to it, "including admitted exhibits and testimony presented during the competency hearing," the district court found that Hawkins was both presently competent to stand trial and had been competent to stand trial in January 2008. However, the court found that the law of the case required it to retry the case. The Supreme Court held that the language in the trial court record regarding a retroactive competency determination and the State being free to retry Hawkins if he was found presently competent, was not the law of the case. Because there was no legal analysis on the subject of retroactive competency determinations and no factual discussion from the Court of Appeals as to why one would not be possible in this case, the Supreme Court read that court's conclusory statement as an acknowledgement that it had no record on which to base a retroactive competency determination. Therefore the Court reversed the district court and remanded the case for further proceedings. View "Idaho v. Hawkins" on Justia Law

Plaintiff-Appellant Larry Hansen was involved in an automobile accident with Defendant-Respondent Matthew Roberts. At trial, Plaintiff sought to recover damages for his injuries and Defendant sought to recover property damage for his vehicle. The jury found Plaintiff to be 90% at fault and awarded Defendant damages for his vehicle. Plaintiff appealed the district court's decision to allow Defendant's experts, an accident reconstructionist and a biomechanical engineer, to testify. Plaintiff also appealed the district court's ruling that he waived his objections to Defendant's deposition testimony. Finally, Plaintiff appealed the district court's decision to grant Defendant's motion in limine so far as it limited him from asking whether prospective jurors or one of their family members were or had ever been employed by an insurance carrier. Finding no abuse of the district court's discretion, the Supreme Court affirmed. View "Hansen v. Roberts" on Justia Law

The issue before the Supreme Court in this case concerned the grant of summary judgment dismissing an action to enforce an oral agreement to guaranty the debt of another on the ground that the agreement was barred by the statute of frauds. Sunshine Secretarial Services subleased office space from Accelerated Paving, Inc., and at times provided it with secretarial services. Accelerated Paving owed Plaintiff-Appellant Mickelsen Construction, Inc. money ($34,980.00) for providing asphalt to an Accelerated jobsite. Mickelsen threatened to file a materialmen’s lien against the real property on which the work was being done, and Accelerated's vice president asked that it not do so because that would delay the receipt of payment for the construction job. The vice president offered to pay the debt with an American Express credit card, but Mickelsen responded that it did not accept American Express credit cards. There was disagreement as to what happened next: Accelerate's vice president said there was not enough credit on the card to fund the payment, but when Accelerated received payment for the project it would pay down the balance so that there was enough credit to pay Mickelsen with the card. Mickelsen agreed not to file the lien if Accelerated could find someone to guaranty the payment by the credit card. Defendant-Respondent Lesa Horrocks of Sunshine agreed to do so and gave Mickelsen a check in the amount owed, drawn on Sunshine's account. Sunshine had a credit card machine that was capable of transacting with several credit cards including American Express credit cards. They told her that American Express had approved the transaction and asked her to use Sunshine credit card machine to run the transaction. It appeared to her that the transaction had been approved by American Express. issued the check. Several days later, Accelerated informed her that American Express had not approved the transaction. Accelerated then filed for bankruptcy. Mickelsen then sued Ms. Horrocks and Sunshine alleging that they had agreed to guaranty the credit card payment and so issued the check. The Defendants filed a motion for summary judgment, arguing that the alleged guaranty was barred by the statute of limitations in Idaho Code section 9-505. In response, Mickelsen argued that the check was a sufficient writing under the statute of frauds and, if not, that the transaction was governed by Idaho Code section 9-506 and therefore exempt from the statute of frauds. The district court held that the check was an insufficient writing and that section 9-506 did not apply because the Defendants did not receive any direct benefit. The court granted the motion for summary judgment and entered a judgment dismissing this action. Mickelsen then appealed. Finding no error with the district court's decision, the Supreme Court affirmed. View "Mickelsen Const v. Horrocks" on Justia Law

This appeal stemmed from a protracted contract dispute arising out of the construction of Meridian’s new City Hall. The City brought suit against the project’s construction manager, Petra, Inc., alleging that Petra breached the parties’ agreement in a number of ways. The City further claimed that Petra was not entitled to any additional fees for its work. Petra counterclaimed, seeking an equitable adjustment of its construction manager fee. After trial, the district court entered its findings of fact and conclusions of law, ruling against the City on all but one of its claims and awarding Petra an additional fee for its services. The court awarded Petra $595,896.17 in costs and $1,275,416.50 in attorney fees, but stayed enforcement of the judgment pending appeal. The City appealed. Finding no error in the district court's judgment in favor of Petra, the Supreme Court affirmed. View "City of Meridian v. PETRA Inc." on Justia Law

Plaintiff-Appellant Brian Woodworth brought suit against the State and the City of Nampa to recover damages for injuries he sustained while pushing a shopping cart across a state highway. Both defendants moved for summary judgment. Following a motion hearing, the court granted both motions. The district court granted summary judgment in favor of the State on two separate grounds: (1) the State was entitled to immunity from suit; and (2) regardless of immunity, the court found that Woodworth failed to raise a genuine issue of material fact that the State acted negligently. Following the summary judgment ruling, Woodworth reached a settlement with Nampa whereby the City was dismissed from the case. Woodworth filed an appeal with regard to the court’s dismissal of his claim against the State. Upon review of the district court record, the Supreme Court concluded that the district court correctly applied the immunity test as outlined in applicable precedent. Because Woodworth failed to present a viable negligence claim against the State, the Court affirmed the district court's judgment. View "Woodworth v. Idaho Transportation Bd" on Justia Law

Defendant-Appellant Russell G. Jones appealed his conviction by jury on two counts of rape. The case was initially heard by the Idaho Court of Appeals, which affirmed on one count and reversed on the second. Defendant sought review, which the Supreme Court granted in order to consider the force and resistance necessary with respect to a charge of forcible rape. Given the weight and quantity of the unrefuted evidence across the board, versus the one statement regarding Defendant and the victim, the Court concluded that the district court erred in admitting certain statements made between Defendant and the victim, and that the admission of that statement was harmless. There was insufficient evidence on the element of resistance to support the conviction of forcible rape on Count II so the Court did not consider the issue of force. The conviction on Count II was accordingly reversed. View "Idaho v. Jones" on Justia Law