Justia Idaho Supreme Court Opinion Summaries

Pro se plaintiff Martin Bettwieser brought a breach of contract action against the New York Irrigation District and its directors (collectively, the District). Bettwieser alleged that the District breached an oral contract by not timely providing him with a legal opinion regarding whether he could be excluded from the irrigation district without paying statutory exclusion and filing fees. Following a bench trial, the district court issued findings of fact and conclusions of law, ruling that Bettwieser had failed to demonstrate that he was entitled to relief. Bettwieser appealed, alleging the district court made errors of fact and law during the trial and in its decisions regarding Bettwieser's pre- and post-trial motions. As a preliminary matter, the Supreme Court noted that Bettwieser's briefing was, "at best, difficult to follow. In some cases, it is unclear what issue Bettwieser is attempting to raise. And, even where an issue is identifiable, argument, authority, and legal reasoning are often absent." The Court concluded that the district court's findings of fact and conclusions of law were supported by substantial competent evidence. Bettwieser failed to satisfy the requirements for certification of a class action. The district court was not obligated to consider claims not raised by the pleadings. The district court did not abuse its discretion in denying Bettwieser's motion to disqualify counsel. Bettwieser was not entitled to declaratory judgment because he failed to demonstrate the existence of an actual or justiciable controversy. View "Bettwieser v. New York Irrigation Dist." on Justia Law

In 2006, Woodrow John Grant pleaded guilty to aggravated battery; he successfully completed a period of retained jurisdiction and was placed on probation. In 2009, Grant was charged with possession of methamphetamine, domestic battery, aggravated assault, and unlawful possession of a firearm. Grant's appointed counsel moved to withdraw, stating that Grant had reneged on an agreed-upon plea bargain and that communications between them had broken down. The district court denied the motion. Later, Grant pled guilty to possession of a controlled substance and domestic battery, and admitted to violating the terms of his probation. The district court considered a letter and live testimony from the victim of Grant's domestic battery, in which the victim expressed her opinions on Grant's crime, character, and the sentence that would be proper for him. Thereafter, the district court sentenced Grant to five years fixed and five years indeterminate for domestic battery, to be served concurrently with a sentence of two years fixed and three years indeterminate for possession of methamphetamine. The district court revoked Grant's probation and executed his previously suspended sentence of four years fixed and six years indeterminate. The two new sentences were to be served consecutively to the reinstated 2006 sentence. Grant requested leniency in three I.C.R. 35 motions, which the district court denied. Grant appealed, arguing that the district court erred by refusing to allow his counsel to withdraw, by considering the victim's impact statements in their entirety, and by refusing his requests for leniency. Finding no error, the Supreme Court affirmed the district court in all respects. View "Idaho v. Grant" on Justia Law

In 2011, the Idaho Department of Health and Welfare (the Department) initiated this action to terminate the parental rights of John Doe. The matter proceeded to trial where the magistrate court found that Doe had neglected and abandoned his minor child, D.C., and that it was in the best interest of the child that Doe's parental rights be terminated. Doe appealed and the Supreme Court affirmed: Doe failed to show that the magistrate erred in finding that he had abandoned D.C. "Even if the Department failed to implement the case plan in an appropriate fashion, the magistrate's finding of neglect was supported on a prong of neglect essentially independent of case plan performance. Doe has made no effort to show that it is not in the best interest of D.C. to terminate Doe's parental rights. There are no grounds to reverse the termination order." View "Health & Welfare v. Doe" on Justia Law

Michelle Anderson appealed the district court's denial of her motion to dismiss kidnapping charges brought against her for keeping the child she had with Ricky Anderson away. Michelle was obligated to deliver the child to Ricky under a parenting plan issued by a Montana court, but never completed the exchange. In her motion to dismiss, Michelle argued that Ricky is not a custodial parent under I.C. 18-4501 and therefore Michelle could not have committed kidnapping. The district court denied the motion, and the Supreme Court granted permission to appeal that decision. Upon review, the Supreme Court concluded that Ricky was a custodial parent for the purposes of IC 18-4501(2), and that Michelle could be charged with kidnapping based on Ricky's visitation rights that granted him lawful care and control of the child. Accordingly, the Court affirmed the district court's decision. View "Idaho v. Anderson" on Justia Law

Justin S. Reynolds, Kristine Reynolds, and their construction company, Sunrise Development, LLC (Reynolds) brought a malpractice action against their law firm, Trout Jones Gledhill Fuhrman, P.A., and its attorney-employee, David T. Krueck. Reynolds alleged professional negligence in both the drafting of a real estate agreement between Reynolds and Quasar Development, LLC, and in the subsequent handling of the litigation regarding that agreement. The district court granted summary judgment in favor of Trout Jones, holding that the two-year statute of limitations found in Idaho Code section 5-219(4) applied to bar the action and Reynolds timely appealed. Upon review of the matter, the Supreme Court affirmed. View "Reynolds v. Trout, Jones, Gledhill, Fuhrman, P.A." on Justia Law

The issue in this case came from an appeal of a decision of the Industrial Commission which found that claimant Joseph Henry failed to prove that the heart attack he suffered while at work was an industrial accident because his cardiologist could not determine whether the plaque rupture that caused the heart attack was triggered by events occurring before or after the claimant arrived at work. Upon review, the Supreme Court held that the Commission’s findings of fact were not clearly erroneous and affirmed its order denying compensation. View "Henry v. Dept of Corrections" on Justia Law

The issue before the Supreme Court in this case arose from a commercial lease dispute. Boise Mode, LLC leased space in its building to Donahoe Pace & Partners, Ltd. (DPP). Timothy Pace executed a personal guarantee for the lease. During the term of the lease, Boise Mode remodeled part of the building for another tenant. After raising concerns to Boise Mode about the adverse effects of the construction to its business, DPP eventually stopped paying rent and vacated the premises prior to the end of the lease. Boise Mode then brought an action against DPP, alleging breach of contract, and against Pace for breaching the guarantee. DPP counterclaimed, alleging that the disruption caused by the construction constituted breach of contract and constructive eviction. After Boise Mode moved for summary judgment on all claims and counterclaims, DPP requested a continuance to complete discovery. The district court denied DPP's motion and ultimately granted Boise Mode's motion for summary judgment. DPP appealed the grant of summary judgment as well as the district court's denial of its request for a continuance. Upon review, and finding no error, the Supreme Court affirmed. View "Boise Mode, LLC v. Donahoe Pace" on Justia Law

A bail bond company challenged the district court's decision affirming an order of the Director of the Idaho Department of Insurance. That order, which was based on I.C. 41-1042, prohibited a bail bond company from contemporaneously writing a bail bond and contracting with a client to indemnify the company for the cost of apprehending a bail jumper. It also prohibited a bail bond company from later requiring a client to agree to such indemnification as a condition of the bond's continuing validity. While the proceedings before the district court were pending, the Director promulgated I.D.A.P.A. 18.01.04.016.02, which by rule expressed the Final Order. Upon review of the applicable statutory authority and the trial court record below, the Supreme Court concluded that: (1) the plain text of I.C. 41-1042 permits a bail bond company to contemporaneously write a bail bond and contract with a client to indemnify the company for the cost of apprehending a defendant who jumps bail; and (2) the Director's interpretation of I.C. 41-1042 prejudiced PetitionerTwo Jinn's substantial rights. The Court reversed the district court's memorandum decision and remanded the case for further review. View "Two Jinn, Inc. v. Idaho Dept of Insurance" on Justia Law

Appellant Camas County appealed an injunction granted by the district court against the enforcement of Camas County Ordinances 150 and 153, and Resolutions 96 and 103 (2007 zoning amendments). Plaintiff-Respondent George Martin opposed the zoning amendments at a public hearing of the Camas County Board of Commissioners. In late 2008 while this case was still being adjudicated, Martin filed a complaint for declaratory judgment against 2008 zoning amendments. Camas County removed the case to the federal district court, which ultimately granted Martin's requested relief to the 2007 amendments. The federal district court then remanded the case to the state district court. Martin was granted attorney fees and costs as a result of the federal district court's order; the court held that Camas County acted without a reasonable basis in fact or law. Camas County appealed, maintaining that the district court abused its discretion in ordering the injunction and should have awarded the County attorney fees. Upon review, the Supreme Court found that the 2007 and 2008 zoning amendments were practically identical. Both cases involved the same property owned by Martin in Camas County. Thus, the facts between this case and the underlying case "Martin I" (concerning the 2007 amendments) were nearly identical. . . . as such, Martin properly conceded that the district court's injunction against the 2007 zoning amendments should have been reversed. Martin also properly conceded that his award of attorney fees by the district court also should have been reversed. The County was not entitled to a fee award. View "Martin v. Smith" on Justia Law

Plaintiff-Appellant Jerry Doherty appealed a district court order that dismissed him as a party in the medical malpractice action against respondents Dr. Gordon Dixon and Blackfoot Medical Clinic. The district court, on September 16, 2010, ruled that because Doherty failed to disclose this claim as an asset in his Chapter 13 bankruptcy proceeding, he was judicially estopped from pursuing this claim against Respondents. The district court further ordered that Doherty take nothing from Respondents, and that the bankruptcy trustee be substituted as the party-plaintiff. On appeal, Plaintiff argued that the district court abused its discretion in granting summary judgment. Finding no abuse of discretion, the Supreme Court affirmed. View "McCallister v. Dixon" on Justia Law