Justia Idaho Supreme Court Opinion Summaries

Interfaith Sanctuary Housing Services, Inc. (IFS) applied for a conditional use permit (CUP) to operate a large-scale low-barrier shelter home in Northwest Boise. The Planning and Zoning Commission (PZC) initially denied the application, citing concerns about compatibility with the neighborhood, undue burden on public facilities, adverse effects on nearby properties, and insufficient information on mitigating adverse impacts. IFS appealed to the Boise City Council, which reversed the PZC’s decision and granted the CUP, imposing 30 conditions of approval. The Veterans Park Neighborhood Association, Inc. (VPNA) sought reconsideration, which was denied, and then petitioned the district court for judicial review.The district court upheld the City Council’s decision, finding no error in the Council’s actions. VPNA appealed to the Idaho Supreme Court, arguing that the City Council’s decision was arbitrary and capricious, based on unlawful procedure, and that the Council’s reasoned statement was inadequate under the Local Land Use Planning Act (LLUPA).The Idaho Supreme Court found that the City Council’s decision was arbitrary and capricious and based on unlawful procedure because the PZC’s determination that the CUP could not be conditioned into compliance with the CUP criteria was not an error. The Court also found that the City Council’s reasoned statement was conclusory and failed to adequately resolve pertinent factual disputes, thus violating LLUPA and depriving VPNA of due process. The Court concluded that VPNA demonstrated a prejudice to its substantial rights.The Idaho Supreme Court reversed the district court’s decision and remanded the case with instructions to invalidate the City Council’s approval of the CUP. VPNA was awarded costs but not attorney fees on appeal. View "Veterans Park Neighborhood Association, Inc. v. City of Boise" on Justia Law

Manuel and Melissa Rose purchased property from the F & M Martino Family Trust, with Fred and Michelle Martino acting as trustees. The warranty deed did not reference a previously recorded Boundary Line Agreement (BLA) that established a barbed wire fence as the boundary between the Roses' property and the neighboring property owned by Donald and Marylee Meliza. The Melizas later obtained a survey showing the fence was on the Roses' property and filed a quiet title action for the disputed strip of land. The Roses sought defense from the Martinos, who refused, leading the Roses to file a third-party action for breach of warranty of title and breach of the covenant of seisin.The district court granted summary judgment in favor of the Martinos, finding that the BLA was a "matter of record" and thus excluded from the warranty deed. The court also denied the Martinos' request for attorney fees. The Roses appealed the summary judgment decision, and the Martinos cross-appealed the denial of attorney fees.The Supreme Court of Idaho reversed the district court's summary judgment decision, holding that the warranty deed's language was clear and unambiguous and did not exclude the BLA. The court found that the Martinos breached the covenant of seisin by not owning the entire property described in the deed and breached the warranty of title by failing to defend the Roses in the quiet title action. The court affirmed the district court's decision to deny attorney fees to the Martinos, as the case did not involve a commercial transaction and the warranty deed did not contain an attorney fee provision. The case was remanded for further proceedings consistent with the Supreme Court's opinion. The Roses were awarded costs on appeal. View "Rose v. Martino" on Justia Law

BrunoBuilt, Inc. contracted with William and Amy Dempsey to build a home in the Boise Foothills. With the help of insurance agent Randy L. Richardson, BrunoBuilt purchased a Tailored Protection Policy (TPP) from Auto-Owners Insurance Company, which included "Builders' Risk" coverage. The policy excluded damage caused by landslides. In 2016, the Dempsey project was not included in the TPP renewal, allegedly due to Richardson's negligence. Shortly after, the nearly completed Dempsey home was damaged by a landslide. BrunoBuilt sued Richardson and Auto-Owners, claiming Richardson negligently failed to advise about landslide coverage and failed to renew the Dempsey project. BrunoBuilt also claimed Auto-Owners was vicariously liable for Richardson's negligence.The District Court of the Fourth Judicial District of Idaho granted summary judgment in favor of Auto-Owners, concluding Richardson was not acting as Auto-Owners' agent and that the policy excluded landslide damage. BrunoBuilt appealed.The Supreme Court of Idaho reviewed the case and found that the district court erred in granting summary judgment. The court held that the 2015 policy, which excluded only naturally occurring landslides, might still apply because Auto-Owners did not provide the required notice of the reduction in coverage in the 2016 policy, which excluded both naturally occurring and human-caused landslides. The court also determined that Auto-Owners bore the burden of proving the applicability of the landslide exclusion. The case was reversed and remanded for further proceedings to determine whether the 2015 policy's coverage continued and whether Richardson was acting as Auto-Owners' agent when he failed to renew the policy. The court did not award attorney fees to either party. View "BrunoBuilt, Inc. v. Auto-Owners Insurance Company" on Justia Law

Dustin Clover sustained injuries while removing irrigation drip tape from a seed field while working for Crookham Company in 2018. Clover filed a complaint against Crookham, alleging that his injuries fell within an exception to the exclusive remedy rule under the Worker’s Compensation statutes, which allows for a separate civil action if the employer commits an act of “willful or unprovoked physical aggression.” Crookham moved for summary judgment, arguing that Clover failed to provide evidence supporting his claim. The district court agreed and granted summary judgment in favor of Crookham. Clover’s motion for reconsideration was also denied, leading to this appeal.The district court of the Third Judicial District of Idaho found that Clover’s injuries occurred during the course of his employment and were covered by worker’s compensation. The court concluded that Clover did not present sufficient evidence to show that Crookham’s actions fell under the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The court noted that there were no prior incidents or complaints about the drip tape lifter’s safety and that Crookham had used the equipment for nine seasons without injury.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The court held that Clover failed to demonstrate that Crookham consciously disregarded knowledge that the drip tape lifter was unsafe. The court also found that the district court did not abuse its discretion in excluding certain evidence and denying Clover’s motion for reconsideration. The court concluded that Clover did not present new facts sufficient to raise a genuine dispute of material fact. Consequently, the district court’s grant of summary judgment and denial of the motion for reconsideration were affirmed. Crookham was awarded costs as the prevailing party on appeal. View "Clover v. Crookham Company" on Justia Law

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law

A mother and her fiancé filed a petition to terminate the biological father's parental rights and allow the fiancé to adopt the child. The mother did not serve the father with the petition, and he did not participate in the proceedings. The magistrate court terminated the father's parental rights and granted the adoption. The father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. The magistrate court denied the second motion, citing res judicata. The district court reversed this decision, finding that the father's due process argument warranted consideration.The Idaho Supreme Court reviewed the case. The court held that the father's Rule 60(b)(4) motion, which alleged a fundamental error violating his constitutional right to due process, was not barred by res judicata. The court applied the fundamental error doctrine, which allows for exceptions to procedural bars when a fundamental constitutional right is at stake. The court also rejected the mother's arguments that the father's motion was barred by the doctrines of claim splitting, invited error, appellate waiver, and the law of the case.The Idaho Supreme Court affirmed the district court's decision to remand the case to the magistrate court for an evidentiary hearing to determine whether the father's Rule 60(b)(4) motion was timely and whether the termination and adoption judgment was void. The court also awarded the father partial attorney fees on appeal for defending against certain arguments made by the mother. View "Doe v. Doe" on Justia Law

Sherry Cole filed a formal complaint against Rocky Mountain Power (RMP) alleging she had been overbilled due to her power meter being cross-connected with her neighbor’s. Initially, an RMP employee confirmed the cross-connection and credited her account with $1,256.45. However, subsequent tests revealed no cross-connection, leading RMP to remove the credit and instead apply a $450 credit for the inconvenience. Cole then filed a complaint with the Idaho Public Utilities Commission, which dismissed her complaint due to lack of evidence of overcharging. Cole's motion for reconsideration was also denied by the Commission.Cole appealed to the Idaho Supreme Court. The Commission had reviewed Cole’s complaint, RMP’s billing calculations, and an analysis by Jon Kruck, an investigator, which concluded that Cole’s energy usage was consistent and did not indicate a cross-connection. The Commission found no substantial evidence supporting Cole’s claims and dismissed her complaint. Cole’s petition for reconsideration was denied as she failed to present new evidence or demonstrate that the dismissal was unreasonable or unlawful.The Idaho Supreme Court affirmed the Commission’s decision, finding that the Commission’s factual findings were supported by substantial and competent evidence. The Court noted that Cole relied on anecdotal evidence and did not provide sufficient proof to counter the Commission’s findings. Additionally, the Court held that Cole’s constitutional arguments were waived as they were raised for the first time on appeal and were not supported by sufficient legal authority. The Court also denied Cole’s request for attorney fees, as pro se litigants are not entitled to such fees.The Idaho Supreme Court affirmed the orders of the Idaho Public Utilities Commission dismissing Cole’s complaint and denying her petition for reconsideration. View "Cole v. IPUC" on Justia Law

Husband and Wife divorced in 2020, with Husband required to pay child support and attorney fees. Two years later, Wife initiated a contempt proceeding against Husband for failing to comply with the divorce decree. On the day of the contempt trial, Husband informed the court he was unable to attend due to vehicle issues. The magistrate court proceeded with the trial in his absence, found him in criminal contempt, and sentenced him to 70 days in jail, with 50 days suspended, and ordered him to pay additional attorney fees.The district court affirmed the magistrate court's decision to hold the trial in Husband's absence but reversed the incarceration sanction, finding insufficient evidence that Husband waived his right to counsel. The district court concluded that the magistrate court violated Idaho Rule of Civil Procedure 75(l)(1) by imposing incarceration without an attorney present to represent Husband.The Idaho Supreme Court reviewed the case and determined that the magistrate court erred in holding the contempt trial in Husband's absence. The court held that a contemnor's right to be present at a criminal contempt trial is protected under the Sixth Amendment, similar to a criminal defendant's right. The court concluded that Husband's willful absence did not constitute a knowing, intelligent, and voluntary waiver of his right to be present. The proper procedure would have been to issue a writ of attachment to ensure Husband's attendance.The Idaho Supreme Court reversed the district court's decision and remanded the case with instructions to vacate the order of contempt and remand to the magistrate court for further proceedings. The court also found the district court's failure to address Wife's request for attorney fees harmless, as Husband's appeal was not frivolous. No attorney fees were awarded on appeal, and costs were awarded to Husband. View "Salazar v. Salazar" on Justia Law

Medical Recovery Services, LLC (MRS), a medical debt collector, sought to collect $460 from Katrina Melanese (now Katrina Sullivan) for an emergency room visit in September 2017. Sullivan was treated at Eastern Idaho Regional Medical Center (EIRMC) by Intermountain Emergency Physicians (IEP), which did not collect insurance information directly from patients. Sullivan provided her insurance information to EIRMC, but IEP billed her outdated insurance information from a previous visit. When the outdated insurers denied the claim, IEP assigned the bill to MRS for collection.The magistrate court ruled in favor of Sullivan, finding that an implied condition precedent existed, requiring IEP to bill Sullivan’s insurance before seeking payment from her. The district court affirmed the magistrate court’s decision, agreeing that the condition precedent was not satisfied because IEP did not make reasonable efforts to obtain Sullivan’s correct insurance information.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The court held that an implied-in-fact contract existed between IEP and Sullivan, and that the contract included a condition precedent requiring IEP to bill Sullivan’s insurance before seeking payment from her. The court found substantial and competent evidence supporting the magistrate court’s finding of the condition precedent, noting that Sullivan provided her insurance information to EIRMC and that IEP’s general practice was to bill insurance before seeking payment from patients. The court also rejected MRS’s argument that the federal Emergency Medical Treatment and Labor Act (EMTALA) prevented the application of the condition precedent in emergency room settings.The court concluded that IEP failed to make reasonable efforts to satisfy the condition precedent and, therefore, MRS could not collect the debt from Sullivan. The court awarded attorney fees and costs on appeal to Sullivan. View "Medical Recovery Services, LLC v. Melanese" on Justia Law

Jennifer and Jesse Smith divorced in 2017 after fifteen years of marriage. Jennifer, a stay-at-home mother, and Jesse, a construction superintendent, entered into a Marital Settlement Agreement requiring Jesse to pay Jennifer spousal support until January 1, 2025. The agreement included a "Review Term" stating that spousal support would be reviewed every two years. In 2018, Jesse unilaterally reduced the spousal support payments and later stopped paying altogether, leading Jennifer to file a breach of contract action.The magistrate judge dismissed Jesse's petition to modify the spousal support due to a non-merger clause, which kept the spousal support provision outside the court's jurisdiction. Jennifer then sought partial summary judgment in district court, arguing that the Review Term was too vague to be enforceable. The district court agreed, striking the Review Term but upholding the rest of the spousal support provision under the agreement's severability clause. The jury found Jesse in breach of the agreement and awarded Jennifer $76,514 in damages, plus attorney fees and costs.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the Review Term was unenforceable due to its vagueness, indefiniteness, and uncertainty. The court also upheld the district court's application of the severability clause, maintaining the enforceability of the remaining spousal support provision. Jennifer was awarded attorney fees and costs on appeal as the prevailing party. View "Smith v. Smith" on Justia Law