Justia Idaho Supreme Court Opinion Summaries

Plaintiff-Appellant Dr. John Noak was dismissed as the medical director for Prison Health Services, Inc. (PHS). He appealed the district court's grant of summary judgment in favor of the Idaho Department of Correction (IDOC) on claims of breach of an implied covenant of good faith, intentional and negligent infliction of emotional distress, defamation, and intentional interference with contract. A 2004 investigation into how Plaintiff treated a female inmate at an IDOC facility lead to IDOC demanding that PHS replace Plaintiff as medical director. Finding no error in the district court's judgment, the Supreme Court affirmed the grant of summary judgment in favor of IDOC. View "Noak v. Dept. of Corrections" on Justia Law

Plaintiff Minor Miracle Productions, LLC (MMP) was a film company for whom Third-Party Respondent David Richards worked. MMP provided a film location and funding for a film written and directed by Defendant Randy Starkey. After the film was completed, Starkey refused to turn over possession of the film and various pieces of equipment from the film. MMP brought suit against Starkey alleging breach of the duty of loyalty, breach of contract, and conversion. After initially appearing via counsel in the case, Starkey proceeded pro se. When Starkey failed to appear at motion hearings and disregarded the district court’s orders regarding discovery, the court sanctioned Starkey, striking his defenses and precluding him from using any evidence not previously disclosed. MMP then moved for judgment on the pleadings, and the district court granted the motion. The court ordered Starkey to pay Richards over one million dollars in damages and interest for the costs of the film’s production, to return the film and to release the copyrights to the film and its website to Richards, and enjoined Starkey from selling the film and from using any of the equipment related to the film. Starkey timely appealed. Upon review, the Supreme Court affirmed the district court's grant of judgment on the pleadings. View "Minor Miracle Productions, LLC v. Starkey " on Justia Law

Idaho Development, LLC (Idaho Development) advanced $1,100,000.00 to Teton View Golf Estates, LLC (Teton View), a joint venture made up of Idaho Development as a 33.3% owner and Rothchild Properties, LLC as a 66.7% owner. Teton View granted Idaho Development a promissory note secured by a deed of trust that specified a set monthly payment and stated that the entire amount was to be paid off in ninety days. Idaho Development filed an action to foreclose on the deed of trust after Teton View failed to satisfy the promissory note. DePatco, Inc., another lienholder on the property, filed a motion for summary judgment to recharacterize Idaho Development’s advance as a capital contribution, which was granted. Idaho Development appealed, arguing that there was a genuine issue of fact as to whether the entire $1,100,000 advance was intended to be a capital contribution. Idaho Development also appealed a subsequent summary judgment brought by ZBS, LLC, which relied on the recharacterization determination in holding that ZBS’ lien on the property had priority over Idaho Development’s lien. Upon review of the trial court's recharacterization of Idaho Development's lien, the Supreme Court concluded that there was a genuine issue of fact as to whether the entire $1,100,000 was intended to be a capital contribution, the district court therefore improperly granted summary judgment. The case was remanded for further proceedings. View "Idaho Development, LLC v. Teton View Golf Estates, LLC " on Justia Law

In Plaintiff T.J.T., Inc.'s second appeal from a summary judgment in favor of Defendant Ulysses Mori, in which the district court found that the non-competition agreement Mori allegedly breached was unenforceable under California law. This case arose from the execution of a non-competition agreement between TJT and Mori in connection with the sale of Mori’s business, Leg-It Tire Company, Inc., to TJT in 1997. Leg-It owned and operated one production facility in Woodland, California. TJT also operated in the tire and axle recycling business, and it had recycling facilities in Idaho, Oregon, and Washington at the time it purchased Leg-It in 1997. At the time of the sale of Leg-It, Mori was hired as the "Senior Vice President and General Manager of the Leg-it Tire Company Division of [TJT]." In 2000, Mori moved to Idaho and took a new position as Corporate Sales Manager. In 2007, Mori resigned as an employee of TJT and several days later, was hired by West States Recycling, Inc., a competitor to TJT, as a tire and axle salesman. In his employment with West States, Mori facilitated the opening of a warehouse facility in Idaho to support local Idaho customers who purchase tires and axles, and also solicited tire and axle business in Oregon, Washington, California, and Idaho. Because the Supreme Court in its review found that the district court erred in failing to consider whether and to what extent the agreement could be "blue penciled" to make it enforceable, the Court vacated the summary judgment and award of attorney fees and remanded the case for further proceedings. View "T.J.T., Inc. v. Mori " on Justia Law

The issue on appeal in this case stemmed from a 2005 real estate purchase and sales agreement (PSA) entered into between Pines Grazing Association as the seller, and J.C. Investments (owner of Flying Joseph Ranch) as the buyer of the Pines Ranch. Prior to closing, the parties learned that approximately 80 acres of what Pines had previously believed to be a portion of Pines Ranch was omitted from the ranch's legal description. Pines retained attorney Fred Snook to assist with the acquisition of the 80 acres. Mr. Snook determined that the 80 acres had been deeded to Lemhi County and that the County still owned the land. In light of this, the parties entered an addendum to the PSA whereby they would proceed with the original closing on the ranch while giving Pines time to try to acquire the 80 acres from Lemhi County in order to sell the 80 acres to Flying Joseph Ranch. The sale closed before the parties learned that Lemhi County could not sell the 80 acres privately; the land had to be sold at public auction. Pines sent Mr. Snook to the auction to bid on the 80 acres. The parties' agents cut a side deal whereby Pines would be paid not to bid on the 80 acres. Flying Joseph ultimately won the land at auction. Flying Joseph's agent faxed Pines' agent an agreement and release of all claims for the 80 acres. Pines refused to sign, believing that the agreement was not part of the oral agreement not to bid at the auction. Pines subsequently filed suit to enforce the terms of the oral contract. Among the issues brought before the Supreme Court were whether the district court erred in denying Appellant’s motion for JNOV on the grounds that the $20,000.00 offered to refrain from bidding constituted an unauthorized brokerage commission. Upon review, the Supreme Court refused to enforce the oral agreement not to bid at the auction because it was an illegal contract in violation of the Sherman Act. "As such, the parties are left as they are with respect to the oral agreement not to bid, and neither party is entitled to attorney fees on appeal or in the district court with respect to all issues related to the oral agreement not to bid." The Court upheld the jury's finding that Pines did not breach the grazing lease. View "Pines Grazing Association, Inc. v. Flying Joseph Ranch, LLC " on Justia Law

Appellant Two Jinn, Inc. appealed a district court's decision that affirmed a magistrate's denial of its motion to set aside a bond forfeiture. Two Jinn argued that it demonstrated a defense of impossibility of performance based on the deportation of Rosendo Arriago Navarro (Navarro). Two Jinn also argued that the district court abused its discretion in failing to recognize that justice did not require enforcement of the forfeiture in this case under former Idaho Criminal Rule 46(e)(4). Navarro was arrested for driving without privileges. Navarro was released from custody when Two Jinn dba Aladdin Bail Bonds/Anytime Bail Bonds posted his $500 bail. After pleading guilty, Navarro was ordered to appear in court for sentencing. Navarro failed to appear for his sentencing hearing, the bond was ordered forfeited, and a bench warrant was issued for Navarro’s arrest. 175 days after the bond had been forfeited, Two Jinn filed a motion to set aside that forfeiture and exonerate it from its liability on the bond, arguing that Navarro had been deported to Mexico and that it was, therefore, entitled to relief under the contract law doctrine of impossibility of performance. Upon review, the Supreme Court concluded that the magistrate court did not abuse its discretion in denying Two Jinn’s requested bond exoneration. Therefore, the Court affirmed the district court decision upholding the magistrate court decision. View "Idaho v. Two Jinn, Inc." on Justia Law

Petitioner Virginia Beaudoin appealed a district court's dismissal of her motion for summary judgment on a breach of fiduciary duty claim against Defendant Davidson Trust Company. The claim stemmed from Davidson Trust’s mistaken distribution of trust funds to Beaudoin when Beaudoin’s two children were, in fact, the designated beneficiaries. Because the Supreme Court found that Davidson Trust owed Petitioner no fiduciary duty at the time of the alleged breach, the Court affirmed the district court's decision dismissing Petitioner's claim. View "Beaudoin v. Davidson Trust Co. " on Justia Law

The issue before the Supreme Court in this appeal was the City of Lewiston's rejection of a bid for a public works project on the grounds that the lowest bidder lacked sufficient experience for the project. In 2009, the City of Lewiston (City) advertised for bids to replace the irrigation system at the City golf course. Hillside Landscape Construction, Inc. (Hillside) desired to bid on the project, but prior to doing so it sent a letter to City stating that if City insisted upon having qualifications other than a current Idaho public works license to bid on the project, the City must follow the Category B procedures set forth in the Idaho Code and pre-qualify the bidders. Hillside asked that the qualification of prior experience be removed. City’s attorney denied the request, stating that City’s specifications and bidding process complied with state law. Hillside and four others submitted bids for the project. City notified the bidders that Hillside Landscape Construction submitted the lowest bid but that the company lacked the required experience specified within the bid documents. City awarded the contract to Landscapes Unlimited, the next lowest bidder. Hillside filed a complaint seeking injunctive relief, declaratory relief, and damages. The district court held that City complied with the bidding statutes, vacated a temporary restraining order, denied the motion for an injunction then dismissed Hillside’s complaint. In its review, the Supreme Court found that because the City chose to follow the "Category A" procedures set forth in the Idaho Code rather than the Category B procedures, the district court erred in holding that City could reject the bid on that ground. The Court therefore vacated the judgment of the district court and remanded the case for further proceedings. View "Hillside Landscape Construction, Inc. v. City of Lewiston " on Justia Law

In 2002, Defendant David Egan, a business manager for Defendant Foxhollow Construction and Trucking, Inc. (Foxhollow), met with Wayne Johnson of Defendant L.N. Johnson Paving, LLC (Johnson) to discuss a bid for excavation and paving work for a new public high school. Foxhollow wanted to bid on the project but lacked the requisite public works license. Johnson thought its license could cover Foxhollow if the two companies submitted a bid in Johnson's name. Egan submitted a subcontract bid in Johnson’s name to Plaintiff Harris, the general contractor for the school project, and was the successful bidder. Over the course of the business relationship, a contract dispute arose. Harris brought this action, alleging that (1) Foxhollow, Johnson, and another subcontractor breached their subcontracts with Harris. Egan filed a counterclaim for indemnification from Harris. The district court dismissed Foxhollow as a party for lack of proof of notice because there was no indication that Foxhollow was ever served. After a bench trial, the court granted Harris’ motion for "directed verdict" as to Egan’s counterclaim. The court concluded however that Harris failed to prove any of its remaining claims against any of the defendants and therefore was not entitled to relief. The court also awarded fees and costs to Johnson. On appeal to the Supreme Court, Harris argued that the district court: (1) erred in concluding Harris failed to prove contract damages; (2) erred in concluding that no defendant was unjustly enriched; (3) erred in concluding that no defendant is liable for fraud; (4) erred in concluding that Harris was not entitled to indemnity; (5) abused its discretion in denying Harris’ motion to amend findings and conclusion; (6) abused its discretion in granting fees and costs to Johnson; and (7) abused its discretion in denying Harris’ motion for a new trial. Upon review, the Supreme Court affirmed the district court's judgment except for its attorney fee awards, which were vacated. View "Harris, Inc. v. Foxhollow Construction & Trucking, Inc. " on Justia Law

Plaintiff Jon Wakelum and Mike Ressler attended an auction of three parcels of property owned by Defendant Thomas Hagood that was conducted by Bullock and Company Realtors (Bullock). The auction was advertised as an absolute auction with a variety of terms and conditions for bidders. Wakelum and Ressler offered the high bids for the three parcels, all totaling less than $1 million. When Hagood was approached with the purchase and sale agreements, he refused to sign them. He claimed he had no intention to sell the properties for less than $2 million. Wakelum and Ressler brought suit against Hagood, arguing that the auction sale was enforceable. They later amended the complaint to include a claim that Hagood violated the Idaho Consumer Protection Act (ICPA) and attempted to further amend the complaint to seek a declaratory judgment that Bullock, as agent for Hagood, had authority to sign the purchase agreements. The district court granted Hagood’s motion for summary judgment and dismissed Wakelum’s and Ressler’s claims. The district court denied Wakelum’s and Ressler’s second motion to amend their complaint, finding that even if their claims were proven, they would not have been entitled to relief. Wakelum and Ressler appealed. Upon review, the Supreme Court reversed the district court's holding that the Bullock's Representation Agreement (that listed the terms and conditions with bidders) with Hagood was unenforceable for failing to comply with the statute of frauds. The case was remanded for further proceedings. View "Wakelum v. Hagood " on Justia Law