Justia Idaho Supreme Court Opinion Summaries

Claimant Gary Brown filed a complaint with the Industrial Commission seeking disability benefits after he injured his back while working for The Home Depot. Arguing that the injuries caused by the accident in combination with his preexisting conditions, left him permanently and totally disabled, Claimant sought workers' compensation benefits from both Home Depot and the Idaho Industrial Special Indemnity Fund (ISIF). The Commission determined that Claimant was not permanently and totally disabled. Claimant contended on appeal that the Commission erred by evaluating his ability to find work based upon his access to the local labor market at the time his medical condition stabilized in 2005. He argued that his labor market access should have been evaluated as of the date of the Commission hearing in 2009. He also argued that the Commission based its finding that he was 95 percent disabled on an incorrect understanding of the expert testimony presented at the hearing. Upon review, the Supreme Court held that Claimant's labor market at the time of the disability hearing was the proper labor market to be used in evaluating his disability. But because the Commission applied an incorrect legal standard, the Court vacated the Commission's decision and remanded the case for further proceedings. View "Brown v. Home Depot" on Justia Law

Appellant Lincoln McNulty worked as a ski patroller for Sinclair Services Company as a member of the Sun Valley Resort from 2005 to 2010. Once the ski season ended in 2009, Appellant filed for unemployment benefits effective April 2009, through November 2009. During those off-season months, he began working part-time at the Sawtooth Club for extra income. However, Appellant failed to report such employment or any earnings from the Sawtooth Club to the Idaho Department of Labor when he filed for unemployment benefits each week. The Idaho Department of Labor discovered the discrepancy and a claims investigator spoke with Appellant and ultimately issued an Eligibility Determination that Appellant was ineligible for benefits because he willfully made false statements or failed to report material facts in order to obtain benefits. Appellant appealed to the Supreme Court, arguing that his failure to report was not willful, the facts were not material, and that he should be eligible for a waiver of the requirement to repay the unemployment benefits. Upon review, the Court affirmed the Industrial Commission's conclusion that Appellant willfully failed to disclose material facts in order to obtain unemployment benefits and that he must repay the overpayment of both state and federal benefits as well as any applicable interest and penalties. View "McNulty v. Sinclair Oil" on Justia Law

On June 28, 2010, Appellant Maria Gomez filed a Worker’s Compensation Complaint with the Industrial Commission (Commission) claiming benefits for an accident that occurred in 2009, when she injured her lower back lifting sixty-pound boxes. The injury occurred at Blackfoot Brass (Dura Mark). Appellant had previously suffered two work-related accidents while working with Dura Mark, one in 2002, the other in 2006, but had returned to work without restrictions after participating in physical therapy for both injuries. The issue before the Supreme Court centered on a Commission order denying reconsideration of Appellant's motion to reopen the record to allow for additional evidence on the issue of causation. The Industrial Commission previously ordered that Appellant had failed to prove the medical treatment she received for a back injury was related to an industrial accident and injury. At the emergency hearing pursuant to the Judicial Rules of Practice and Procedure adopted by the Commission, Appellant introduced evidence regarding her entitlement to reasonable and necessary medical care pursuant to I.C. 72-432, but the referee denied Appellant's claim on the grounds of causation. Upon review, the Supreme Court affirmed the Commission's judgment. In doing so, the Court wanted to provide a "clear message that without a specific stipulation that causation will be a contested issue at the hearing pursuant to I.C. 72-713, and especially if there is a difference of opinion as to causation by opposing parties and their experts, claimant’s attorneys should no longer be lulled by anything other than a stipulation to all legal prerequisites and elements for recovery and be prepared to present evidence of a causal connection between the industrial injury or sickness and the required treatment." View "Gomez v. Dura Mark, Inc." on Justia Law

Fall River Rural Electric Cooperative hired Plaintiff-Appellant Suzette Bollinger as a cashier and receptionist at its Ashton headquarters in 1988. She was terminated in 2009 despite having satisfactory performance without cause. Plaintiff alleged in her complaint that she signed an employment contract at the time of her hiring, but she failed to produce the contract at trial. In 2009, Fall River adopted an "at-will" employment policy which expressly superseded any prior conflicting policy. Plaintiff ultimately sued Fall River for: (1) breach of express and implied contract, including breach of the covenant of good faith and fair dealing; (2) retaliatory discharge and wrongful termination in violation of public policy; and (3) negligent and intentional infliction of emotional distress. The district court granted summary judgment to Fall River on all of Plaintiff's claims. The district court also denied her motion for reconsideration, and she timely appealed to the Supreme Court. Finding that Plaintiff's claims were properly dismissed, the Supreme Court affirmed the district court's ruling. View "Bollinger v. Fall River Rural Electric Cooperative, Inc." on Justia Law

Plaintiff-Appellant Thomas Weisel owned two adjacent parcels within the Beaver Springs Subdivision in Ketchum. He sought to unify and develop the lots. At some point, his plan indicated that he intended that construction would take place in a "setback zone" that abutted the lots' shared border. Plaintiff and the Beaver Springs Owners Association executed an agreement whereby Beaver Springs approved the unification and development plan. Construction on the property was completed in 1985, all structures were located on what used to be "lot 14" and the former setback zone and "lot 13" remained vacant. In 2009, Plaintiff filed suit to rescind or reform the agreement. The district court granted Beaver Springs' motion for summary judgment, and Plaintiff appealed. Upon review, the Supreme Court concluded that "[i]n essence, Plaintiff asked the Court to reform an agreement for which the parties freely bargained." As such, the Court found that the district court properly granted summary judgment in favor of Beaver Springs. View "Weisel v. Beaver Springs Owners Association, Inc." on Justia Law

Claimant Brooke Stark worked for Assisted Living Concepts, Inc. from 2008 to 2010 as a "residence director" of one of Assisted Living's facilities. Claimant was called into the sales director's office one day, and the two talked about a rumor that one of Assisted Living's other facilities was imminently closing. Later that evening, Assisted Living's divisional director of human resources called Claimant to ask where Claimant heard of the closing rumor. Claimant did not disclose her source. Five minutes following that call, Assisted Living's chief executive officer called Claimant (with the director of HR on the call) to ask about the rumor. Claimant said she talked to a number of people, but that she did not want to share the information. The CEO emphasized the importance of knowing who started the rumor so that the company could reassure those involved that the facility in question would not close. Still declining to reveal her source, the CEO suspended Claimant. The human resources director, after a little investigation, found that Claimant violated company policy by refusing a direct order from her supervisor. Claimant was then terminated in the fall of 2010. The issue before the Supreme Court involved whether Claimant's refusal to respond to the CEO's question. The Industrial Commission held that Claimant's refusal to obey the direct order did not constitute misconduct under the Employment Security Law. The Supreme Court held as a matter of law, Claimant's conduct was indeed misconduct under the Employment Security Law, and reversed the Industrial Commission. View "Assisted Living Concepts , Inc. v. Idaho Dept of Labor" on Justia Law

This case arose from a district court's dismissal for failure to exhaust administrative remedies of Petitioner-Appellant Daniel Fuchs's petition for judicial review and complaint for declaratory and injunctive relief. Petitioner challenged the Alcohol Beverage Control's (ABC) removal of his name from liquor license priority waiting lists. He argued that the agency's action constituted an informal rule that was not promulgated in accordance with the Idaho Administrative Procedure Act (Idaho APA). In response, ABC argued that Petitioner failed to exhaust administrative remedies before bringing his action before the district court, and that the removal was done in accordance with Idaho APA. Upon review, the Supreme Court found that the district court erred in finding that Petitioner failed to exhaust administrative remedies, but that Petitioner did not have a property interest in his place on the priority list (since the legislature did not have the authority to create such an interest). Accordingly, the Court affirmed the district court's decision. View "Fuchs v. Idaho" on Justia Law

Jane Doe appealed the termination of her parental rights with regard to her son, John Doe, contending that the magistrate court failed to properly consider her improved participation in mental health and family counseling services. Because there was substantial and competent evidence to support the magistrate court's final Judgment that termination of Jane Doe's parental rights was in John's best interests, the magistrate court did not err in terminating her parental rights. View "Dept. of Health & Welfare v. Jane Doe" on Justia Law

Plaintiffs-Appellants Randolph Farber, Scott Becker, and Critter Clinic (Farber) alleged that the Manager of the Defendant-Respondent State Insurance Fund (SIF or "the Fund") failed to comply with I.C. 72-915, which provides the means by which the SIF Manager may distribute a dividend to policyholders. The district court determined that the gravamen of Farber's claim implicated the statute and held that the three-year statute of limitation provided by I.C. 5-218(1) barred all claims that accrued prior to July 21, 2003. Farber timely appealed. Upon review, the Supreme Court held that the five-year statute of limitation in I.C. 5-216 applied to Farber's claim. Therefore, the Court reversed the trial court's decision and remanded the case for further proceedings. View "Farber v. Idaho State Insurance Fund" on Justia Law

Defendants-Appellants Stanley and Catherine Jensen, as trustees of the Stanley and Catherine Jensen Family Living Trust, appealed the district court's decision that granted Plaintiff-Respondent Rocky Mountain Power's motion for summary judgment. Defendants are record owners of a cattle ranch that lies within a corridor established by the Utility for a 345 kilovolt transmission line. The Utility sought a perpetual easement and a right of way for the Utility and its successors and assigns to locate, construct, reconstruct, operate, and maintain a 150 foot wide high-voltage overhead power line utility corridor through the eastern part of Defendants' property. In 2008, Defendants entered into an Occupancy Agreement with the Utility, waiving all defenses to the Utility's acquisition of the easement, except the claim of just compensation. Upon execution of the Agreement, Defendants were paid $215,630 which would be deducted from any final determination of just compensation for the easement. Under the terms of the Occupancy Agreement, if just compensation was determined to be less than $215,630, Defendants were not required to return the difference. The parties were unable to reach an agreement for just compensation within a specified time, so the Utility filed its Complaint in early 2009, seeking a decree of condemnation, an award of easement, and specific performance of the Occupancy Agreement. The Utility filed a motion for summary judgment, contending that Defendants did not identify any expert witnesses or laid a proper foundation for any probative evidence of just compensation. Upon review, the Supreme Court found that Defendants failed to establish a genuine issue of material fact to establish the fair market value of their property. Accordingly, the Court affirmed the district court's judgment. View "Rocky Mountain Power v. Jensen" on Justia Law