Justia Idaho Supreme Court Opinion Summaries

Neurosurgeon Donald Blaskiewicz, M.D. went to work for the Spine Institute of Idaho (the “Spine Institute” or the “Institute”) in 2018. The Spine Institute entered into a Professional Services Agreement (the PSA) with Blaskiewicz containing a non-compete clause, contractually proscribing Blaskiewicz from practicing medicine within fifty miles of the Spine Institute’s office (with an explicit exception for Caldwell) for a period of eighteen months, should his employment with the Spine Institute be terminated for any reason. Pursuant to the PSA, Blaskiewicz had two ways to avoid the non-compete clause: he could either get permission from the Spine Institute to practice medicine within the proscribed area, or he could pay the Spine Institute $350,000 in “liquidated damages.” The PSA also required any disputes to be resolved by arbitration. Less than a year and a half after hiring Blaskiewicz, the Spine Institute terminated his employment. Blaskiewicz filed suit in district court, seeking a declaratory judgment that the non-compete clause was unenforceable. The district court concluded that the non-compete clause was against public policy and void as a matter of law, and granted summary judgment in favor of Blaskiewicz. The Idaho Supreme Court reversed, finding the district court did not cite or analyze the statutes governing non-compete agreements in Idaho. The Court concluded there were genuine issues of material fact such that summary judgment was inappropriate as to whether the non-compete provision was void as a matter of public policy or otherwise enforceable. View "Blaskiewicz v. Spine Institute of Idaho" on Justia Law

Brandon and Brandi Kelly married on April 20, 2015, and had a child on June 9, 2015. Brandon filed for divorce on May 30, 2017. This appeal primarily concerned their disputes regarding the division of property and attorney fees. Prior to marriage, Brandon and Brandi entered into a prenuptial agreement (“the PNA”) seeking to establish their rights to various items of property. Brandi and Brandon were represented by separate counsel during the negotiation and execution of the PNA. Before signing the PNA, Brandi reviewed Brandon’s 2014 tax return. Brandi’s attorney requested changes to the PNA’s definitions of separate and community property, which were made. Brandi expressly waived her right to review other financial documentation concerning Brandon’s assets and signed the PNA. During the pendency of the divorce action, and relevant to this appeal, Brandon filed four motions for partial summary judgment and Brandi filed two motions for partial summary judgment, each of which required interpretation of various provisions of the PNA. After review, the Idaho Supreme Court affirmed in part, and reversed in part, certain district court decisions with respect to the parties' PNA. The Supreme Court found the district court erred (1) in affirming the magistrate court’s decision that the PNA barred Brandi from requesting attorney fees for child custody, visitation and support matters; (2) in affirming the magistrate court’s summary judgment decision concluding that Brandon’s payments from EIRMC were his separate property; and (3) when it failed to vacate the award of attorney fees to Brandon for his contempt motions, but did not err when it affirmed the magistrate court’s other deductions from Brandi’s separate property award. View "Kelly v. Kelly" on Justia Law

After receiving reminder notices by mail, the insureds failed to pay a renewal premium for a rented home by the due date. Fourteen days after payment was due, the insureds mailed a check to the insurance company for the late renewal premium. Six days later, but before the insurance company reviewed the late payment, a fire occurred at the home. Two days after the fire, the insurance company returned the late payment, denied coverage for the loss, and denied reinstatement of the policy. The insurance company subsequently brought a declaratory judgment action against the insureds. The district court granted summary judgment in favor of the insurance company. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "United Heritage v. Zech" on Justia Law

Andrew Ashmore, agent for appellant Breckenridge Property Fund 2016, LLC, (“Breckenridge”) arrived at a foreclosure sale with endorsed checks to support Breckenridge’s bid. Jesse Thomas, agent for Cornerstone Properties, LLC, (“Cornerstone”) was also present. Before the auction, the auctioneer provided Ashmore and Thomas a packet of paperwork. The last page contained a requirement that endorsed checks would not be accepted as payment for a bid. Because Ashmore only had endorsed checks, the auctioneer gave Ashmore one hour to cure the payment defect, but the auction eventually proceeded with Ashmore unable to secure a different form of payment. The property ultimately sold to Cornerstone. Breckenridge filed a complaint against the two respondents and a third defendant, alleging: (1) violations of Idaho Code section 45-1506; (2) estoppel; and (3) negligence/negligence per se, seeking mainly to void the sale to Cornerstone. Breckenridge also recorded a lis pendens against the property. The district court ultimately entered summary judgment for all defendants and quashed the lis pendens. The Idaho Supreme Court found the district court abused its discretion in awarding attorney fees to Cornerstone and the auctioneer under Idaho Code section 12-120(3). The judgment was affirmed in all other respects. View "Breckenridge Property Fund 2016, LLC v. Wally Enterprises, Inc., et al." on Justia Law

Erick Pena filed a declaratory action against Viking Insurance Company of Wisconsin (“Viking”), alleging the automobile insurance policy he purchased was illegal because it provided illusory minimum limits of UIM coverage. Pena then filed a motion for summary judgment asking the court to declare that the UIM coverage was illusory. Viking filed a cross-motion for summary judgment, arguing that the policy was not illusory because it provided tangible benefits to a group of insured persons and that the offset provision in the policy complied with Idaho public policy. The district court granted Viking’s motion for summary judgment. Pena timely appealed. After review, the Idaho Supreme Court reversed, finding the policy at issue indeed provided illusory coverage. View "Pena v. Viking Insurance Company" on Justia Law

Robert, David, and Troy Taylor were partners in a commercial fire prevention business based in Alaska. Troy later formed his own business that directly competed with the partnership. In January 2015, Robert, David, and Troy signed an eight-paragraph agreement (“the Agreement”) that settled all potential legal claims relating to Troy’s competing business. The Agreement provided that Robert and David would buy Troy’s interest in the partnership. In exchange, Troy agreed to pay Robert and David $30,000 each and not work in the fire prevention industry in Alaska and Nevada. In March 2018, Robert and David brought this action in Idaho alleging, among other things, that Troy had breached the Agreement by working for a competing fire prevention business in Nevada. Troy counterclaimed, asserting Robert and David had breached the Agreement. Robert and David voluntarily dismissed some claims and the district court dismissed the rest. In addition, the district court granted summary judgment in Troy’s favor on his breach of contract counterclaim. Robert and David appealed, challenging the district court’s rulings that: (1) the noncompete provision in the Agreement was unenforceable; (2) the Agreement was severable and enforceable without the noncompete provision; and (3) they could not assert an affirmative defense of excusable nonperformance based on their allegation that Troy materially breached the Agreement. After review, the Idaho Supreme Court found the district court only erred in finding the noncompete clause was severable from the Agreement as a matter of law. The Court affirmed in all other respects. View "Taylor v. Taylor" on Justia Law

Mike Von Jones (“Jones”) appealed the denial of his motion to set aside a sheriff’s sale and the award of attorney fees to Safaris Unlimited LLC (“Safaris”) under Idaho Code section 12-120(5). A jury found there was an enforceable contract between Jones and Safaris, and that Jones breached the contract. Safaris petitioned for and obtained a writ of execution requiring the sheriff to execute upon Jones’s personal and real property, including a pending lawsuit against Jeremy Sligar and Overtime Garage, LLC. At the sheriff’s sale, Safaris (the only bidder present) bought the lawsuit for $2,500.00 via a credit bid. Although Jones received notice of the sheriff’s sale, neither Jones nor his representative attended. Jones did, however, file a motion to set aside the sheriff’s sale of the Sligar Lawsuit. Then Safaris executed on additional personal property of Jones. The sale returned $8,300.00. While both Jones’s and Safaris’ appeals were pending, Jones tendered a $119,238.04 check to the clerk of the court in an attempt to satisfy the remainder of the amended judgment. The district court granted Safaris’ motion for release of funds and determined that the deposited funds were sufficient to satisfy the amended judgment. However, the district court found that the deposited funds exceeded the amount owed by $2,500.00 because Jones’s tender did not account for Safaris’ credit bid to purchase the Sligar Lawsuit. The district court held that Jones had not demonstrated a gross inadequacy of consideration because he failed to establish the litigation’s approximate value. Similarly, Jones failed to show very slight additional circumstances because he could not point to any procedural irregularities “pertaining to either the notice or conduct of the sale.” After denying Jones’s motion to vacate the sheriff’s sale, the district court ordered the clerk of the court to release the remaining $2,500.00 from the tender back to Jones or his attorneys. Jones timely appealed, arguing: (1) the district court erred by concluding Jones’s monetary tender to the clerk of the court did not preclude Safaris from claiming ownership of Jones’s pending lawsuit; (2) the district court abused its discretion by denying his motion to set aside the sheriff’s sale; and (3) the district court erred in awarding costs and fees pursuant to section 12-120(5) for actions taken after Jones’ tender to the clerk. Finding no reversible error, the Idaho Supreme Court affirmed the district court's orders. View "Safaris Unlimited, LLC v. Jones" on Justia Law

Brent Meyer appealed pro se a district court’s judgment granting Adam Walker’s breach of contract claim against him. Walker hired Meyer to assist him with the demolition and remodel of a home he had purchased in Soda Springs, Idaho. Walker alleged that in June 2018, the parties entered into an agreement in which Walker agreed to pay Meyer $18,000 in exchange for Meyer’s labor on the home. This contract was subsequently modified by the parties as Meyer performed work on other areas of the home not covered by the contract and Walker paid Meyer more money than provided in the original contract – roughly $60,000. On October 16, 2018, Walker fired Meyer from the job, alleging the labor was not up to industry standards and did not add value to the home. Walker hired another contractor to fix or redo the work completed by Meyer and his subcontractors. Meyer argued the district court erred in concluding he was not a “construction professional” as defined by Idaho’s Notice and Opportunity to Repair Act (“NORA”), Idaho Code sections 6-2501–04, and claimed the case should have been dismissed because Walker failed to comply with the notice requirement of NORA. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Walker v. Meyer" on Justia Law

Nathan Smith appealed a district court order granting summary judgment in favor of his former employer, Kount, Inc., and denying his cross motion for summary judgment on the grounds that the compensation agreement he signed unambiguously required Smith to remain employed until a specified date to earn the bonus compensation, and Smith resigned before that date. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Smith v. Kount Inc." on Justia Law

SRM Arms, Inc. (“SRM”) filed suit against GSA Direct, LLC, (“GSA”) and FFL Design, LLC, (“FFL”) (collectively, the “Entity Defendants”), and Anthony Turlington, David Lehman, and Ryan Fitzgerald (collectively the “Individual Defendants”), alleging breach of contract, breach of the covenant of good faith and fair dealing, fraud, aiding and abetting in the commission of fraud, and unjust enrichment. After the jury awarded verdicts for SRM, all Defendants asked the court to modify the judgments or grant a new trial. The district court entered a remittitur for the claims against the Entity Defendants because it found the amount the jury awarded was excessive and not supported by sufficient evidence at trial. On appeal, SRM argued the district court erred in reducing the awarded damages. In their cross-appeal, the Entity Defendants argued the jury improperly found fraud and improperly found FFL liable for GSA’s debts. The Entity Defendants also argued the damages should have been reduced further. Additionally, the district court granted the Individual Defendants’ motion for a new trial on liability and damages because it found the jury instructions were inadequate to distinguish between direct liability and alter-ego liability. On appeal, SRM argues the jury correctly determined direct liability and associated damages. The Idaho Supreme Court affirmed in part, reversed in part and remanded in part. Regarding the Entity Defendants, the Supreme Court reversed and remanded for reconsideration of the remittitur, or in the alternative, a new trial, in light of the Supreme Court's conclusion that a possible alternate basis for the jury’s verdict could exist. The Supreme Court affirmed the district court’s decision upholding the verdict of fraud against GSA and FFL. The district court’s decision to uphold the verdict that FFL is liable to SRM was also affirmed; the Court found the statute of frauds was satisfied and not, as the jury decided, because an exception to the statute of frauds applied. The Court reversed the district court’s decision to uphold the finding of unjust enrichment and remanded for further consideration of whether there was substantial and competent evidence in the record supporting the jury’s award of damages against FFL for both breach of an implied-in-fact contract and unjust enrichment. Regarding the Individual Defendants, the Supreme Court affirmed the district court’s granting of a new trial on liability against the Individual Defendants. The district court’s award of a new trial on damages against the Individual Defendants was also affirmed. View "SRM Arms, Inc. v. GSA Direct, LLC" on Justia Law