Justia Idaho Supreme Court Opinion Summaries

This appeal arose from Stan and Donna Griffiths' divorce. Donna appealed the trial court's decisions: (1) denying her motion to dismiss Stan’s appeal; and (2) reversing in part and affirming in part the magistrate court’s division of the marital estate. On appeal, Donna argued the district court erred in denying her motion to dismiss Stan’s intermediate appeal pursuant to the acceptance of the benefits doctrine. Donna further argued the district court erred in reversing several of the magistrate court’s rulings, including its valuation of hospital ownership shares, its award of an equalization payment to Donna, and its award of spousal maintenance to Donna. Stan cross-appealed, arguing that the district court erred in affirming the magistrate court’s admission of expert testimony and unequal division of marital property. After review of the trial court record, the Idaho Supreme Court determined the district court did not err in denying Donna’s motion to dismiss the appeal pursuant to the acceptance of the benefits doctrine, and did not err in affirming the magistrate court's admission of expert testimony. However, the district court erred in reversing the magistrate court’s valuation of the MVH Class A units, and erred in concluding that the magistrate court failed to consider Stan’s tax consequences. Further, the Supreme Court concluded the trial court erred in reversing Donna's equalization payment award, and in remanding her spousal maintenance award. Judgment was affirmed in part and reversed in part. The matter was remanded for further proceedings. View "Griffiths v. Griffiths" on Justia Law

In the summer of 2014, Mark and Jennifer Porcello sought to purchase property In Hayden Lake, Idaho. After making various pre-payments, the amount the couple was still short on a downpayment. Mark and Jennifer could not qualify for a conventional loan themselves. They hoped another property in Woodinville, Washington, owned by Mark’s parents, in which Mark and Jennifer claimed an interest, could be sold to assist in the purchase of the Hayden Lake property. In an effort to help Mark and Jennifer purchase the property, Mark’s parents, Annie and Tony Porcello, obtained financing through a non-conventional lender. "In the end, the transaction became quite complicated." Annie and Tony’s lawyer drafted a promissory note for Mark and Jennifer to sign which equaled the amount Annie and Tony borrowed. In turn, Mark signed a promissory note and deed of trust for the Hayden Lake house, in the same amount and with the same repayment terms as the loan undertaken by his parents. In mid-2016, Annie and Tony sought non-judicial foreclosure on the Hayden Lake property, claiming that the entire balance of the note was due and owing. By this time Mark and Jennifer had divorced; Jennifer still occupied the Hayden Lake home. In response to the foreclosure proceeding, Jennifer filed suit against her former in-laws seeking a declaratory judgment and an injunction, arguing that any obligation under the note had been satisfied in full when the Woodinville property sold, notwithstanding the language of the note encumbering the Hayden Lake property. Annie and Tony filed a counter-claim against Jennifer and a third-party complaint against Mark. A district court granted Jennifer’s request for a declaratory judgment. However, by this time, Annie and Tony had died and their respective estates were substituted as parties. The district court denied the estates’ request for judicial foreclosure, and dismissed their third-party claims against Mark. The district court held that the Note and Deed of Trust were latently ambiguous because the amount of the Note was more than twice the amount Mark and Jennifer needed in order to purchase the Hayden Lake property. Because the district court concluded the note and deed of trust were ambiguous, it considered parol evidence to interpret them. Ultimately, the district court found the Note and Deed of Trust conveyed the Hayden Lake property to Jennifer and Mark “free and clear” upon the sale of the Woodinville property. Annie’s and Tony’s estates timely appealed. Finding that the district court erred in finding a latent ambiguity in the Note and Deed of Trust, and that the district court's interpretation of the Note and Deed of Trust was not supported by substantial and competent evidence, the Idaho Supreme Court vacated judgment and remanded for further proceedings. View "Porcello v. Estates of Porcello" on Justia Law

This appeal involved the enforceability of a premarital agreement between Julie Neustadt and Mark Colafranceschi. Before the two were married, they entered into a premarital agreement that required Neustadt to obtain a two-million-dollar life insurance policy naming Colafranceschi as the beneficiary. The agreement required Neustadt to keep the policy in force after termination of the marriage. During the divorce proceedings, Neustadt challenged the enforceability of this provision, arguing that the insurance clause was void as against public policy to the extent it applied after divorce. The magistrate court agreed that the contractual provision was void as against public policy. However, on appeal, the district court reversed, concluding the insurance clause did not violate any public policy in Idaho. Neustadt appealrf, arguing that the district court erred in finding the insurance clause valid and enforceable because, following the parties’ divorce, Colafranceschi had no insurable interest in Neustadt’s life. Colafranceschi also filed a cross-appeal, arguing: (1) the magistrate court erred in denying certain discovery requests; (2) the lower court erred by failing to address his objection to Neustadt’s motion in limine; and (3) the lower courts’ erred in their findings that Colafranceschi failed to prove he was fraudulently induced to sign the premarital agreement to get him to return to the couple’s marital home. The Idaho Supreme Court affirmed the district court decision in its entirety: (1) the Insurance Clause was not void as against public policy; (2) any error regarding discovery was forfeited; (3) there was no evidence that the magistrate court coerced Colafranceschi into withdrawing his extreme cruelty claim; and (4) substantial and competent evidence supported the magistrate court’s conclusions that Colafranceschi was not fraudulently induced regarding equity in the Osprey home. View "Neustadt v. Colafranceschi" on Justia Law

Angela Johnson and Patrick Murphy met online and began dating in 2014. When Angela discovered she was pregnant, she left Boise and began living with Patrick in his home in Coeur d’Alene. After the birth of their son, the parties resided together for three and a half years. Angela, desiring to end what she considered an “unhealthy relationship,” moved to Boise with the son in 2018. Shortly thereafter, Angela filed a petition in Ada County for paternity, custody, visitation, and support. Following venue being changed to Kootenai County and a trial, the magistrate court awarded the parties joint legal custody and physical custody of the child, with Patrick receiving primary physical custody unless Angela moved back to Coeur d’Alene at which point she and Patrick would share physical custody equally. In an expedited appeal, Angela contended the magistrate court’s decision was an abuse of discretion and required reversal. Finding no such abuse of discretion, the Idaho Supreme Court affirmed the magistrate court’s child custody order. View "Johnson v. Murphy" on Justia Law

A guardian ad litem (GAL) for two minor children appealed after a magistrate court determined the children should have been placed with their biological father in Mexico. Jane Doe I (Daughter) and John Doe II (Son) were removed from the care of their mother (Mother) along with another half-sibling on after a preliminary investigation revealed the children were homeless and living in a car. At the time Daughter and Son were taken into foster care, the specific whereabouts of their biological father, John Doe (Father), were unknown, other than that he had been deported to Mexico in December 2014. Father had last seen the children at that time. In addition, his paternity had not yet been established and he had not had any contact with his children since his deportation. A little more than a year after the proceedings had begun, Father’s paternity was established. Shortly after the Department filed an amended petition, it sought a case plan for Father. The Department also attempted to obtain a home study for Father but faced difficulty accomplishing this task because he lived in Mexico. The children’s GAL opposed placing the children with Father without more information about him and his living situation. Ultimately, the magistrate court ordered that the children be placed with Father as soon as possible without a home study being conducted, apparently relying on In re Doe, 281 P.3d 95 (2012). On motions to reconsider filed by the Department and the GAL, newly-discovered evidence was presented that Father was a registered sex offender who had previously pleaded guilty to failing to register as such. Nevertheless, the magistrate court denied the motions to reconsider. The GAL appealed. After review, the Idaho Supreme Court reversed the magistrate court, holding that while it continued "to recognize that the biological parent’s presumption of fitness is and should be very strong. However, it is not irrefutable. . . . Where the legislature has unequivocally placed a duty on the court and the Department to consider its primary concern 'the health and safety of the child,' it is incumbent on a court to ensure that diligent investigation occurs regarding questions pertaining to children’s safety." View "IDHW & John Doe v. GAL & 4th Judicial District Casa" on Justia Law

In a divorce action between Lexi and Robert Ellis, the magistrate court granted Ms. Ellis’ motion for appointment of a receiver, subject to the express condition that the costs of the receiver would be paid from community funds. The district court affirmed a series of decisions made by the magistrate court relating to Bruce Denney’s efforts to collect payment for services he performed as a receiver and forensic accountant in the Ellis divorce. After the divorce was final, Denney’s accounting firm, Poston, Denney & Killpack, PLLC (“PDK”) moved to intervene to recover payment from Robert Ellis, which the magistrate court granted. Later, the magistrate court granted PDK’s motion for summary judgment and ordered Mr. Ellis to pay one-half of Mr. Denney’s fees. The magistrate court declined to rule on the reasonableness of the fees at that time, determining further proceedings would be necessary. PDK filed a motion for a determination of the reasonableness of fees. After a hearing the magistrate court granted PDK’s motion and held Mr. Denney’s fees were reasonable. The magistrate court also awarded attorney fees to PDK in bringing the action to recover attorney fees. Mr. Ellis appealed to the district court, which upheld the magistrate court’s decision and also awarded attorney fees to PDK on appeal. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Ellis v. Ellis" on Justia Law

"Although seemingly a simple question of statutory interpretation, at its essence this case concerns a profound family tragedy that has left three young girls caught in the middle of a legal battle between four people who love them." The Nelsons were the grandparents of three girls, ages thirteen, eleven, and eight. The Nelsons’ daughter, Stephanie Evans, and their son-in-law, Brian Evans, are the girls’ parents. The Nelsons petitioned a magistrate court seeking to establish visitation rights, but the court dismissed the petition, ruling: (1) the Nelsons lacked standing to file a petition under Idaho’s grandparent visitation statute); and (2) even if the Nelsons had standing, it would still grant summary judgment in favor of the girls’ parents because the Nelsons would be unable to overcome the presumption that fit parents make decisions in their children’s best interests. On intermediate appeal, the district court affirmed the magistrate court’s rulings. The Idaho Supreme Court determined the visitation statute, Code section 32-719, did not restrict when a grandparent could petition for visitation rights. Further, the district court erred in affirming the magistrate court's grant of summary judgment to the Evanses because the Supreme Court found genuine issues of material fact as to whether the Evanses’ decision to terminate all contact between the Nelsons and their children was in their children’s best interests. Judgment was reversed and the matter remanded to the magistrate court for an evidentiary hearing on the merits of the Nelsons' petition. View "Nelson v. Evans" on Justia Law

Jane Doe (Mother) executed a voluntary consent to terminate her parental rights to Son. Mother shortly thereafter filed a motion to rescind her consent. The magistrate court denied the motion. Termination proceedings were then conducted without Mother, her counsel, or a guardian ad litem for Mother being present. Following the hearing, Mother’s parental rights were terminated. Mother appealed the termination of her parental rights. The Idaho Supreme Court determined the magistrate court erred in failing to appoint a replacement guardian ad litem for Mother. "At the time Mother executed the waiver, there was still an outstanding question, recognized but not addressed by the magistrate court, as to Mother’s need for a guardian ad litem. This outstanding question hinged upon the results of Mother’s psychological evaluations, but was never answered despite the availability of these results. It is clear that Mother suffered from significant mental illness. ...However, having identified the earlier need for a guardian ad litem and the continuing need to have a guardian ad litem absent receiving evidence to the contrary, a replacement guardian was never appointed. There is substantial and competent evidence strongly indicating Mother’s ongoing need for a guardian ad litem." The termination was vacated and the matter remanded to the magistrate court for further proceedings. View "DHW v. Jane Doe" on Justia Law

John Doe I (Child) was removed from the care of his paternal grandmother (Grandmother) and his father, John Doe (Father) after a referral was made to the Idaho Department of Health and Welfare (the Department). The Department ultimately petitioned to terminate Father’s parental rights. Father failed to attend scheduled hearings, ceased communicating with the Department, and only sporadically contacted his attorney. Father’s counsel sought several continuances, but eventually the termination trial proceeded. Following trial, the magistrate court found that Father had failed to comply with the case plan and was unable to discharge his parental responsibilities. The magistrate court found it was in Child’s best interests to terminate Father’s parental rights. Father’s principal argument on appeal was that the magistrate court abused its discretion in allowing the Department to amend its petition to terminate by adding a separate, alternate basis for termination, and by granting only a two-week continuance to Father to respond to this alternate theory. Finding no abuse of discretion, the Idaho Supreme Court affirmed. View "DHW v. John Doe" on Justia Law

In an expedited appeal to the Idaho Supreme Court, a magistrate court terminated Jane Doe’s (“Mother”) parental rights after finding clear and convincing evidence that Mother neglected her children, K.M. and R.M., and that termination was in the best interests of the children. Mother did not appeal the magistrate’s finding that she neglected her children. She only appealed the magistrate court’s finding that termination was in the best interests of the children. The magistrate court found Mother’s testimony lacked credibility and relied on other witnesses to find that Mother had neglected her children under Idaho Code section 16-2005(1)(b) because Mother had failed to reunify with her children and had failed to comply with her case plan. According to Mother, termination was not in the best interests of her children because Mother had a close bond with her children, K.M. was not responding well to foster care, there was no evidence of violence between Mother and her children, and Mother tried to the best of her ability to comply with her case plan. The Supreme Court found substantial evidence supported the magistrate court's finding that termination was in the children's best interests, and affirmed. View "Idaho Dept. of Health & Welfare v. Jane Doe (2019-27)" on Justia Law