Justia Idaho Supreme Court Opinion Summaries

Claimant-Appellant Dallas Clark appealed an Industrial Commission order that denied her workers' compensation benefits. Claimant worked for Shari's Management Corporation as an experienced server. During a graveyard shift, she suffered a herniated disc in her back while lifting a heavy tray onto a high shelf. She would later be diagnosed with sciatica attributed to the lifting injury from work. Shari's completed a Report of Injury, interviewing Claimant in the process. The investigator testified that Claimant attributed the injury as "standing wrong" at a salad bar, which left her unable to lift the tray. The Commission concluded after a hearing that Claimant was unable to prove an industrial accident had occurred. The Supreme Court agreed with the Commission and affirmed its order. View "Clark v. Shari's Management Corp" on Justia Law

The issue before the Supreme Court in this case related to the service of four members of the Board of Directors for the Southern Valley County Recreation District. The State brought usurpation actions against Donald Keithly, Yvette Davis, Patrick Cowles, and Michael Smith (the Directors), alleging they usurped their offices as directors of the Recreation District. The State requested they be removed from office and sought a fine against each of them. Upon the parties' cross-motions for summary judgment, the district court ruled that this action was an election contest, rather than a usurpation action, which could be brought by the State. The district court also ruled that the Directors' actions while in office were protected by the de facto officer doctrine. The State appealed, arguing this was a proper usurpation action and the de facto officer doctrine did not apply. The Directors cross-appealed, arguing they are entitled to attorney fees. The Supreme Court concluded the matter was moot and affirmed the district court's order denying attorney fees. View "Idaho v. Keithly" on Justia Law

Utah resident Elham Neilsen wanted to purchase a residence close to the city of Tyler in Smith County, Texas. He contacted Plaintiff-Appellant Holli Telford because he had heard that she knew how to acquire properties through tax or other distress sales and had contacts for obtaining financing for prospective buyers. Mr. Neilsen entered into an agreement with Plaintiff that she would bid on the property and sell it to him after she had obtained the warranty deed. Plaintiff submitted a bid, but did not obtain title to the property because, according to her, it was wrongfully redeemed by the prior owners after she had spent money improving it. She sought specific performance of the alleged contract with Smith County, Texas, or damages for breach of the alleged contract. Defendants moved to dismiss this case for lack of personal jurisdiction. The district court granted the motion and dismissed the case with prejudice as to them and without prejudice as to the other defendants. The Supreme Court affirmed the dismissal for lack of jurisdiction, but vacated the dismissal with prejudice and remanded the for entry of a judgment dismissing the complaint without prejudice. View "Telford v. Smith County" on Justia Law

The issue before the Supreme Court in this case concerned the district court’s holding that Ashton Urban Renewal Agency (AURA) had standing to challenge a property tax exemption granted to Ashton Memorial, Inc., a corporation with real and personal property located within AURA’s revenue allocation area. Specifically, the issue was whether AURA was a “person aggrieved” under I.C. 63-511, and therefore, could appeal the grant of the exemption to the Idaho Board of Tax Appeals (BTA). The Supreme Concluded that AURA was an "person aggrieved" under the statute, therefore it affirmed the district court's decision. View "Ashton Urban Renewal v. Ashton Memorial" on Justia Law

Appellant Lillian Hatheway appealed a district court's grant of summary judgment in favor of the Board of Regents of the University of Idaho and the University of Idaho. Appellant worked for the University as an administrative assistant for nine years before she resigned. She sued for age discrimination, hostile work environment, retaliation, constructive discharge and negligent infliction of emotional distress. Upon review, the Supreme Court concluded the district court correctly dismissed all of Appellant's claims. View "Hatheway v. Bd of Regents - UI" on Justia Law

The Department of Health and Welfare appealed an order that disallowed its attempt to recover assets in a probate proceeding. The Department sought to recover assets of a dead Medicaid recipient for medical assistance payments made on the decedent's behalf from her widower. The magistrate court held that the Department could not reach the separate property of the decedent's spouse. Upon review, the Supreme Court concluded the Department was permitted to seek recovery from the decedent's community property that was transmuted to her widow as his separate property. View "In re Estate of Wiggins" on Justia Law

John Doe was in prison when his son was born. The baby's mother was living with another man, and gave the boy the boyfriend's surname. The baby was abused while in her care; the Department of Health and Welfare took the child into custody. The boyfriend was listed as the putative father in a Child Protective Act (CPA) proceeding; after a DNA test, Doe was substituted as the putative father. Prior to the test, Doe had no prior contact with the child. The Department requested termination of Doe's and the biological mother's parental rights. The mother voluntarily consented to the termination. The Department submitted a new petition, requesting for the first time an "Order of Non-Establishment of Parental Rights." The Department averred that Doe was "not the 'parent' of [Son] as [he had] failed to assert any parental rights to [Son] either by statute or by timely establishing some relationship to [Son]." The magistrate judge entered her Findings of Fact, Conclusions of Law and Nonestablishment of Paternity. Doe timely appealed. He raised two issues: (1) whether under Idaho Code he was entitled to an evidentiary hearing prior to the "nonestablishment" of his parental rights; and (2) whether his due process rights were violated. The Supreme Court concluded that Doe did not show he was entitled to an evidentiary hearing prior to the "nonestablishment" of his parental rights, or that his due process rights were violated. View "Doe v. Idaho Department of Health & Welfare" on Justia Law

The State Board of Dentistry fined Plaintiff-Appellant Lon Peckham, DMD for failing to adequately inform a patient prior to performing a procedure, and for publishing misleading material on his website. The district court affirmed the Board's decision. On appeal, Plaintiff challenged the district court's affirming of the Board's final Order. Upon review of the matter, the Supreme Court found insufficient evidence to support findings that Plaintiff failed to inform a patient prior to performing a procedure or for publishing misleading material. Accordingly, the Supreme Court reversed the district court. View "Peckham, DMD v. State Bd of Dentistry" on Justia Law

Albar, Inc. owned a convenience store, gas station and marina on the Pen Orielle River. In 2003, one of its three underground storage tanks leaked gasoline into the surrounding soil. The tanks were insured through the State's Petroleum Storage Tank Fund. Albar ultimately entered into a consent agreement with the State Department of Environmental Quality to remediate the property and any impacted adjacent properties. In 2005, Albar put the businesses up for sale. Albar made a disclosure regarding the 2003 leak, but that statement would later be found false. JLZ Enterprises was interested in purchasing the property, and relied on the false disclosure. In 2007, JLZ Enterprises sued Albar to recover damages for fraud and breach of contract; to rescind the contract; and to recover damages for negligence against the real estate agent and the broker. The matter was tried to the district court. After hearing the evidence, the court declined to rescind the real estate contract, but found that Albar had breached the contract. The court entered a judgment forclosing the deed of trust on the property and ordering its sale. Albar appealed the grant of JLZ's motion to disallow its costs and attorney fees. Upon review, the Supreme Court found that the district court's decision finding Albar breached the contract was supported by substantial and competent evidence, and that it was not an error for the court to disallow Albar's costs and fees. View "Echo Vanderwal v. Albar" on Justia Law

Appellant Alpine Village appealed a district court's grant of summary judgment in favor of the City of McCall. Alpine sued the City to enforce Ordinance 819 (found to be unconstitutional in a separate proceeding), and argued that the City unlawfully took its property in violation of the federal and state constitutions. Finding that the district court did not err in its finding that Alpine's state law claims were barred for failing to bring them according to the notice requirements of the Idaho Tort Claims Act, and that the federal claims were not ripe for adjudication, the Supreme Court affirmed the district court's decision. View "Alpine Village v. City of McCall" on Justia Law