Justia Idaho Supreme Court Opinion Summaries

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

Subdivision developers Buckskin Properties, Inc. and Timberline Development, LLC (collectively Buckskin) brought suit against Valley County seeking recovery of monies paid to the County for road development, and declaratory relief from payment of any further monies. The district court granted summary judgment to the County and Buckskin appealed. Upon review, the Supreme Court concluded that a governing board may lawfully make a voluntary agreement with a land developer for the funding and construction of new infrastructure. Accordingly, the Court affirmed the grant of summary judgment to the County. View "Buckskin Prop v. Valley County" on Justia Law

In 2008, the legislature enacted legislation to establish the Idaho Education Network (IEN), which was to be a high-bandwidth telecommunications distribution system for distance learning in every public school in the state. Syringa Networks, LLC (Syringa), an Idaho telecommunications company, entered into a “teaming agreement” with ENA Services, LLC (ENA). Pursuant to their agreement, ENA submitted a proposal in response to a request-for-proposals (RFP) with the Department of Administration, although the cover letter stated that both ENA and Syringa were responding jointly to the proposal. Qwest Communications Company, LLC, and Verizon Business Network Services, Inc., also submitted responsive proposals. The proposals were then scored based upon specific criteria; the ENA and Qwest proposals received the highest scores. The Department issued a letter of intent to award contracts to Qwest and ENA. One month later, it issued amendments to the two purchase orders to alter the scope of work that each would perform. Qwest became "the general contractor for all IEN technical network services" (providing the “backbone”) and ENA became "the Service Provider." The effect of these amendments was to make Qwest the exclusive provider of the backbone, which was what Syringa intended to provide as a subcontractor of ENA. Syringa filed this lawsuit against the Department, its director, the chief technology officer, ENA and Qwest. The district court ultimately dismissed Syringa’s lawsuit against all of the Defendants on their respective motions for summary judgment. Syringa then appealed the grants of summary judgment, and the State Defendants cross-appealed the refusal to award them attorney fees. Upon review, the Supreme Court affirmed the judgment dismissing all counts of the complaint except count three seeking to set aside the State's contract with Qwest on the ground that it was awarded in violation of the applicable statutes. Furthermore, the Court reversed Qwest’s award of attorney fees against Syringa. We remand to the trial court the determination of whether any of the State Defendants were entitled to an award of attorney fees against Syringa for proceedings in the district court. The Court awarded costs and attorney fees on appeal to ENA. Because the State Defendants and Syringa both prevailed only in part on appeal, the Court did not award them either costs or attorney fees on appeal. View "Syringa Networks v. Idaho Dept of Admin" on Justia Law

Petitioner-Appellant Zane Jack Fields was incarcerated for the 1988 first degree murder of Mary Katherine Vanderford. The district court dismissed his petition for post-conviction relief in 2010, the fifth successive petition for post-conviction relief he filed. In the latest petition, Petitioner argued that the act of destroying an orange camouflage coat (introduced into evidence as a defense exhibit and used by eyewitnesses to identify him) was new evidence that established his innocence. The State moved to dismiss on grounds that Petitioner's newly discovered evidence claims were time-barred by statute, and the district court granted the motion. Upon review, the Supreme Court concluded that the district court was correct in finding Petitioner's petition was untimely filed, and affirmed. View "Fields v. Idaho" on Justia Law

This case arose from a district court's review on appeal of a magistrate court's decision regarding the civil forfeiture of a motorcycle and other items that belong to Christopher Rubey. In 2009, Rubey was arrested and charged with possession of methamphetamine with intent to deliver. Subsequently, the Ada County Prosecutor's Office (State) brought an action under I.C. 37-2744 for civil forfeiture of the motorcycle and related items used in the alleged crime. The magistrate court granted summary judgment to the State, and the district court reversed and remanded that decision. The State appealed to the Supreme Court, arguing that the district court erred in its decision and that the legislative intent behind I.C. 37-2744(a)(4) supports civil forfeiture for either the transportation or trafficking of drugs. Upon review, the Supreme Court agreed and affirmed the district court's decision. View "Ada Co Prosecuting Atty v. 2007 Legendary Motorcycle" on Justia Law

Defendant-Appellant Robert Barton, Jr. was found guilty by jury of solicitation of perjury. Defendant, the victim of aggravated battery, was charged with solicitation and conspiracy to commit perjury in connection to his testimony in the battery case. On appeal, Defendant argued that the jury should have been instructed on his defense of entrapment, and that such a defense was consistent with his plea of innocence. The State disagreed, arguing that no reasonable view of the evidence would support an instruction for entrapment and that such a defense is incompatible with his plea of innocence. Upon review, the Supreme Court found that the district court did not err when it refused to instruct the jury on the affirmative defense of entrapment, and affirmed the decision. View "Idaho v. Barton, Jr." on Justia Law

The issue before the Supreme Court on appeal in this case related to attorney fees incurred in litigation arising from a construction contract for a custom cabin in Island Park, Idaho. There were two issues: (1) whether the district court erred in holding that the Maglebys were entitled to recover only $2,500 from defaulting parties by operation of I.R.C.P. 54(e)(4); and (2) whether the district court erred in its decision regarding the Maglebys' entitlement to post-judgment attorney fees. Upon review, the Supreme Court concluded that I.R.C.P. 54(e)(4) did not limit the Maglebys' fees to the $2,500 pled in their complaint even though defendants did not contest them. The Court vacated the judgments of the district court as they related to attorney fees awards in light of I.C. sec. 12-120(5) and "ITP" and "Jenks." The case was remanded for further proceedings. View "Magleby v. Garn" on Justia Law